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U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES

CENTERS FOR DISEASE CONTROL

NATIONAL INSTITUTE FOR OCCUPATIONAL

SAFETY AND HEALTH 

+ + + + +

ADVISORY BOARD ON RADIATION AND

WORKER HEALTH 

+ + + + +

SUBCOMMITTEE ON DOSE RECONSTRUCTION REVIEWS

+ + + + +

THURSDAY

APRIL 13, 2017

+ + + + +

The Subcommittee convened via 

teleconference, at 10:30 a.m. Eastern Time, David 

Kotelchuck, Chairperson, presiding.

PRESENT:

DAVID KOTELCHUCK, Chairperson

JOSIE BEACH, Member

BRADLEY P. CLAWSON, Member

WANDA I. MUNN, Member

DAVID B. RICHARDSON, Member
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ALSO PRESENT:

TED KATZ, Designated Federal Official

NANCY ADAMS, NIOSH Contractor

BOB BARTON, SC&A

HANS BEHLING, SC&A

KATHY BEHLING, SC&A

ELIZABETH BRACKETT, ORAU Team

RON BUCHANAN, SC&A

GRADY CALHOUN, DCAS

DOUG FARVER, SC&A 

ROSE GOGLIOTTI, SC&A

JOHN MAURO, SC&A

KEITH MCCARTNEY, ORAU Team

JIM NETON, DCAS

STEVE OSTROW, SC&A

BETH ROLFES, DCAS 

MUTTY SHARFI, ORAU Team

SCOTT SIEBERT, ORAU Team

MATT SMITH, ORAU Team

JOHN STIVER, SC&A

ELYSE THOMAS, ORAU Team

JOE ZLOTNICKI, SC&A

 
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Contents

Welcome and Roll Call............................. 4

Three Blind Review Cases from Set 23:............. 6

Lawrence Livermore National Laboratory, ...........6 

Rocky Flats, .....................................38 

Fernald-FMCP. ....................................67 

Category 1 and 2 Cases from Sets 19-21........... 95

including cases covering Oak Ridge, the Gaseous

Diffusion Plants, Savannah River Site, Hanford, AWE 

sites and Other DCAS sites from Sets 14-18

Begin AWE Cases..................................143 

Adjourn......................................... 213
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P-R-O-C-E-E-D-I-N-G-S 

10:34 a.m.

Welcome and Roll Call 

MR. KATZ: This is the Advisory Board 

on Radiation and Worker Health. It's the -- well, 

actually, I didn't hear back from -- do we have 

Grady and Beth on the line?

MS. ROLFES: I'm here, Ted.

MR. KATZ: Okay. That's Beth. 

Okay. This is the Advisory Board on 

Radiation and Worker Health, the Dose 

Reconstruction Reviews Subcommittee. 

For roll call, let me just cover 

conflicts rather than the numbers, but we have a 

quorum. 

(Roll call.)

MR. KATZ: Ok. So in going forward the 

agenda for today's meeting is posted on the NIOSH 

website. This program is part of the website, 

schedule of meetings, today's date, but there's not 

much to the agenda. I think it's easy to follow 

without it. And I think that takes care of 

matters.
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Everyone who is not speaking, please 

mute your phones. That will improve the audio for 

everyone else. If you do not have a mute button, 

press * and then 6. That will mute your phone for 

this conference line. And then pressing * and 6 

again will take your phone off of mute.

Please don't put the call on hold at any 

point because that will cause audio problems for 

everybody. So, no hold. Hang up and dial back in 

if you need to go for a piece.

And now let me continue with the rest 

of the roll call. So let's go to the NIOSH ORAU 

Team and see who's on the line.

(Roll call.)

MR. KATZ: Okay then. And with that 

and no further ado, Dave, it's your meeting.

CHAIR KOTELCHUCK: Okay. Very good. 

Well, let's just start with the blinds and let's 

just do them in the order that we got them. So 

let's do Lawrence Livermore National Lab first. 

Then we'll do Rocky Flats and then FMCP.

Okay? Good. And who will be doing 

that presentation?
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MR. FARVER: This is Doug. I'll take 

that case.

Three Blind Review Cases from Set 23:

Lawrence Livermore National Laboratory

CHAIR KOTELCHUCK: Okay. That's 

good.

MR. FARVER: Go on down to -- well, 

let's talk about Lawrence Livermore. You can go 

down to page 6 and that's where it gets into the 

relevant background information. 

Table 1.1 will show you the cancers that 

are involved. And then the next table on page 7 

gives you a summary of the doses between NIOSH and 

SC&A. And as we look down, we can see that things 

are very similar. There's a little difference in 

the recorded electron dose, and there are some 

differences in the missed dose and the 

environmental dose, and so on, which we'll talk 

about. If we go down to the bottom, you see the 

combined PoC and it's very, very close. So overall 

the doses are very similar.

Okay. If we onto page 8, the employee 

worked at Lawrence Livermore for, gosh, 30 years 
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or so. A long time. Well, let's say -- I won't 

say too much about that. We know the cancers. You 

know where they worked. And we can maybe look at 

Table 2.1, but that just gives you an overall view 

of things. We're going to talk about the 

differences for each one specifically.

So [at] the top of page 10 we talk about 

the recorded photon dose. And both SC&A and NIOSH 

used the same photon distribution and came up with 

the same recorded photon dose. 

Electron doses, Section 2.1.2, were a 

little different mainly because of location, 

because of the location of the cancers. NIOSH used 

an inverse correction factor for the one cancer 

that was on the brow, the eyebrow, and SC&A did not, 

so that results in a very small difference. Other 

than that they were very similar. Same years were 

covered. And so the difference is, you're looking 

at a difference between 125 millirem to 107 rem at 

the bottom of page 10. Not [as] much difference 

as photon dose. Now, there's a little bit 

more difference in the photon dose, partly because 

of the number of badge exchanges that were counted. 
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NIOSH assumed 246 badge exchanges. SC&A counted 

317 badge exchanges. SC&A used an energy 

distribution of 75 percent [for] 30 to 250 keV, and 

25 percent [for] greater than 250 keV. NIOSH used 

100 percent greater than 250 keV, I believe. Let 

me get my table up. 

Yes, they followed OTIB-17. OTIB-17 

says that when you do the difference between the 

shallow and the deep dose, you always record it as 

30 to 250 keV photon dose. 

Okay. 2.1.4 is the missed electron 

dose. SC&A identified five places where the 

positive deep dose was recorded and a blank result 

for the shallow dose. SC&A interpreted the blanks 

as zeros and assigned them missed electron dose. 

It looks like NIOSH set the blank zero result equal 

to the deep dose result based on guidance in the 

external dose TBD. And according to OTIB-17, the 

missed shallow dose is only assigned when the 

shallow dose component is zero and the deep dose 

is non-zero. So if you assume it's zero, then you 

wouldn't assign it. And if not, then you don't. 

In other words, it's another very small difference, 
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between -- I don't know, not a whole lot, a few 

millirem.

Missed neutron dose, Section 2.1.5. 

We have a difference in the number of zeros. NIOSH 

assumed 165 zeros. SC&A assumed 259 zeros. They 

both used the same dose conversion factors and 

energy range. The other slight difference is 

NIOSH assumed the year period was one year less than 

SC&A assumed and it resulted in about 200 millirem 

difference in the total missed neutron dose.

Ambient external dose. SC&A did not 

calculate any ambient external dose based on their 

interpretation of PROC-60 occupational onsite 

ambient dose. SC&A assumed that the employee was 

monitored or missed doses were assigned for all 

years of employment. NIOSH assigned an ambient 

dose of about 146 rem proton, 156 millirem proton, 

37 millirem --

CHAIR KOTELCHUCK: Pardon me, do we 

need to scroll a little bit more? 

MR. FARVER: Okay.

CHAIR KOTELCHUCK: We're on the missed 

neutron dose.
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MR. FARVER: Yeah, I see. I see where 

you're at now. Okay. So there is a slight 

difference. NIOSH made an assumption to assign 

the dose and SC&A did not. 

Occupational medical dose. 

CHAIR KOTELCHUCK: We need some 

scrolling.

MR. FARVER: I can see the medical dose 

on the screen.

CHAIR KOTELCHUCK: I do not. Mine has 

just been fixed here on page 11. Are others having 

trouble?

MEMBER MUNN: No, mine is on 12.

CHAIR KOTELCHUCK: Okay. What's 

going on? I can go over to my CDC machine and look 

at it until things straighten out here. Go ahead. 

I'm sorry.

MR. FARVER: Are we okay?

CHAIR KOTELCHUCK: I'll put myself 

back on mute.

MR. FARVER: Okay. Let's continue on 

with the medical dose. The DOE records show the 

employee received 11 routine X-rays for the time 
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period of employment. NIOSH calculated a dose 

of -- medical doses of 800 or so millirem to the 

back. And you see the other doses. SC&A calculated 

11 routine X-ray exams and assumed a pre-employment 

exam. And that really amounts to the big 

difference in the doses. They were both entered 

the same way, but the only difference is one more 

exam. 

Okay. Internal dose. We can probably 

go to the, yes, top of 13. The employee was 

monitored with urinalysis for, looks like, 4 years, 

5 years out of the 30. And everything was less than 

detectable. Though SC&A made a lot of the same 

assumptions, there's two big differences. One is 

NIOSH assumed and they went through and calculated 

different solubility types. They assumed it was 

a natural uranium material and they determined a 

type-M uranium would be the most 

claimant-favorable. So the dose they came up with 

was about 5 millirem or so.

SC&A, based on the employee's work 

location and job title, assumed it was 

highly-enriched uranium, which explains the 
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difference in the dose. And when SC&A went through

and did the calculation they determined type F 

uranium was the most claimant-favorable, resulting 

in about 100 times more dose. So you're looking 

at 400 millirem. But the big difference there in 

the selection of the type of uranium.

Then we go to the internal dose from 

environmental intakes. Both SC&A and NIOSH 

assumed that there was environmental intake. 

NIOSH assigned doses for the entire work period, 

but adjusted for some partial years. SC&A only 

assumed environmental dose for about 10 years 

because dose was assigned, internal dose was 

assigned for the other years. So NIOSH assumed or 

calculated about 400 millirem and SC&A was less 

than a rem, less than a millirem.

Top of page 14, Table 3.1 shows the 

overall comparison for the external and internal 

dose. You can see the total doses are pretty 

similar and the individual PoCs are very similar. 

We can talk about the few differences. 

In the photon dose, there's a small difference in 

the energy distribution and the number of assumed 
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zero dosimeter readings. And NIOSH assumed 

different zero dosimeter readings. And also for 

the missed neutron doses there's differences in the 

assumed number of missed badge exchanges, and 

that's really the big difference in the neutron 

dose.

You get down to the next page, top of 

page 15. The internal dose: Both assumed a chronic 

intake based on half of the MDA. The two 

differences are SC&A assumed highly-enriched 

uranium; NIOSH assumed natural uranium, which led 

SC&A to a type F uranium and NIOSH to a type M. So 

basically the difference in uranium enrichment was 

the big difference. 

And environmental intake just has to do 

with time periods. NIOSH assumed a 30-year period 

and SC&A assumed about a 10-year period, resulting 

in a difference in doses.

And that about sums it up. Any 

questions?

CHAIR KOTELCHUCK: Questions, 

anybody?

MEMBER MUNN: No, well done.
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CHAIR KOTELCHUCK: A comment. I'm a 

little bothered by the fact that, if we go to 

internal dose over at Table 1.2 it summarizes it 

well. I mean, you have essentially half a rem 

difference. One does it through the different 

assumptions about uranium composition and the 

other with environmental intake. And those two 

happen to balance each other out, but you basically 

differ by a half a rem in each one of those two 

categories. That is, is that accidental? Should 

we view this as accidentally causing them to be 

almost identical, that the two cancel each other 

out but they're different kinds of assumptions?

MR. FARVER: There are, and this is one 

of the things that we've talked about before, the 

employee's job location and job title. Based on 

what the job title was and the building the employee 

worked [in], SC&A quoted the TBD for using, for 

justifying the highly-enriched [uranium].

So I don't -- I'm not that familiar with 

the site. I cannot tell you the difference, but 

it was page 18 of the TBD.

MR. SIEBERT: This is Scott. I can 
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address that if you would like.

MR. FARVER: Yes.

CHAIR KOTELCHUCK: Yes.

MR. SIEBERT: Okay. Yes, the main 

difference is, as Doug was saying, that they made 

an assumption that the employee was in the very 

limited areas where there's highly-enriched 

uranium, and we did not. 

Doug's correct, there are some small 

areas at the site that have highly-enriched 

uranium. We had no indication at all that the 

employee was in those areas. One of them they 

could tie together is -- it's the ore-alloy 

[unintelligible] shop in Building 321C, and the 

individual was in the 321 area, but [was] never 

specified in the area that was using 

highly-enriched uranium.

That alone probably would not be enough 

for us. But if you look in the TBD, one of the 

things that's stated is somebody who was working 

in those areas, they would be doing bioassays for 

enriched uranium. And enriched uranium bioassay 

results are always in units of activity rather than 
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mass units. So all the sample results for the EE 

were in mass units, so that's why we make the 

assumption he was not working with the 

highly-enriched uranium.

CHAIR KOTELCHUCK: Okay. And that 

alone was, as we said, about half a rem, 0.4 rem.

MR. SIEBERT: That's all the 

difference for that one, yes.

CHAIR KOTELCHUCK: Yes. And that 

seems like a -- I mean, sounds to me as if that's 

a good justification for the decisions you made, 

but --

MEMBER CLAWSON: Dave, this is Brad. 

What about the time period where SC&A uses 10 years, 

and that's environmental, I think it was, the 10 

years versus 30 years?

CHAIR KOTELCHUCK: I didn't pick it up. 

Let's talk further about that. 

MEMBER CLAWSON: Did I hear that right, 

Doug?

MR. FARVER: Yes, and I believe that is 

because of the -- we assigned dose for the other 

years, internal dose, so we did not assign 
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environmental for those years. We just used the 

latter years, whereas NIOSH assigned it for the 

entire work period.

MR. SIEBERT: Yeah, and this is Scott. 

Yeah, it's based on the fact -- and we've discussed 

this at other sites as well -- if an individual is 

monitored for, say, uranium, you would not assign 

any environmental uranium during the timeframe 

they were being monitored because it would be 

included in the value that was part of the 

monitoring.

The difference for us is the TBD states 

that over the environmental period, the background 

period of all of his work, there would have been 

gross alpha, gross beta, tritium, plutonium-238, 

-239, and certain isotopes of uranium. What we did 

is we assigned, during the timeframe that the 

individual was -- the whole timeframe they were 

being monitored for uranium, we assigned the other 

things as well as we assigned the uranium during 

the timeframe they were not being monitored for the 

uranium.

The big difference why they got less 
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than one millirem and we got 400-and-some millirem 

is it's the environmental tritium for the whole 

timeframe. That's a pretty large component over 

that timeframe. And it's part of the 

environmental package that we normally assign.

CHAIR KOTELCHUCK: Okay. So really 

those two -- the difference between those two are 

linked, are they not, in the sense of covering --

the period that's covered for missed uranium then 

is not tallied for environmental, which makes 

sense.

MR. SIEBERT: Well, yes and no. I 

mean, they're partially linked because of the 

uranium, but it just happened to balance out that 

their assumption of highly-enriched uranium came 

out to a dose that was pretty darn close to the 

environmental tritium over the same time -- same 

points of timeframe. So those two aren't 

necessarily linked, but they're partially -- they 

partially offset each other.

CHAIR KOTELCHUCK: Right. Right. 

And -- but that's a -- I mean, that's satisfying 

to me to hear this discussion. 
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This is one of those, I think, unusual 

cases. I don't think we've had many [cases] where 

the PoCs are greater than 50 percent. I don't 

think we've looked at many blinds where that's been 

the case. If someone would refresh my memory, I 

don't think we have had too many. And it's good 

to see that they agree quite well.

MS. GOGLIOTTI: We have not had that 

many, but I believe there's like selection criteria 

limited to how high the PoC can be and ways to look 

at it. So I believe it's pretty close to 50 

percent, which is --

(Simultaneous speaking.)

MR. KATZ: Yeah, the top end is 52.

CHAIR KOTELCHUCK: That's right.

MR. SIEBERT: And I believe the 

difference is we've had four and they were all right 

between 50 and 52.

CHAIR KOTELCHUCK: Yeah. So this has 

good agreement and it's good agreement on the far 

side of 50 percent. So any other comments?

MEMBER CLAWSON: Dave, I've got a 

question. 
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Scott, when you were talking about 

this, you were saying the environmental dose is 

because you brought in the tritium, is that 

correct?

MR. SIEBERT: That is correct, yeah.

MEMBER CLAWSON: So my question to you, 

Doug, is what did you do for that tritium? Is 

there -- are we off in that aspect or is there 

another way that you guys were looking at it?

MR. FARVER: Let's see. I am not sure 

if we included tritium.

MEMBER CLAWSON: Well, I was just 

looking at the difference between these two, and 

that's a fairly good sized number. 

CHAIR KOTELCHUCK: Sure.

MEMBER CLAWSON: And I understand what 

Scott's doing. I'm just trying to understand what 

both sides did.

MR. SIEBERT: Brad, this is Scott. My 

guess is -- I'd have to look at the statistics --

but my guess is because SC&A assigned their 

environmental later in the employment period, in 

like the '80s and '90s, most of the tritium 
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environmental was earlier on in the site history, 

if I remember correctly. So if they weren't 

assigning environmental while there was uranium 

monitoring in the earlier years, that's why there 

would be a bigger difference than would necessarily 

normally be assumed. 

MEMBER CLAWSON: Okay. I understand 

that. 

MR. KATZ: Brad, they didn't -- I think 

SC&A didn't understand the nuance between 

environmental covering other exposures than 

uranium. And since the uranium was covered, they 

weren't using the environmental for that period. 

So I think that's the case, that NIOSH has had a --

has a more nuanced understanding of how to apply 

that environmental --

MEMBER CLAWSON: Okay. I just wanted 

to show that that's actually a fairly big 

difference there. And I just wanted to try to 

figure it out, but I appreciate that, Scott.

CHAIR KOTELCHUCK: Yeah. Well, I 

mean, I think that that's -- pardon?

(Simultaneous speaking.)
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MS. GOGLIOTTI: I'm not sure that that 

nuance is always applied at all sites.

MR. KATZ: Well, yeah, I have no idea. 

It just sounds like it was supposed to be applied 

here and it was correctly here.

CHAIR KOTELCHUCK: Right. Which 

suggests to SC&A that while the results came out 

quite similar, and that's very good, maybe in the 

future SC&A should -- you should make sure that you 

pay close attention to that, or closer attention, 

because clearly there are -- tritium intake is 

important.

Okay. Well, is there any further 

discussion by the Subcommittee Members about this? 

If not -- hello?

MEMBER RICHARDSON: Hi. Yeah, this is 

David Richardson. 

CHAIR KOTELCHUCK: Hello, David.

MEMBER RICHARDSON: I think that the 

fact that there's good agreement in the final 

result is one important piece of information. I 

mean, this is one of those examples where 

differences that balance each other out is -- I 
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think to your point, like, is it just a happy 

coincidence or not is something we could think 

about in the future calculating, something like the 

sum of the squared difference at each of these 

calculations as well, so that we would sort of 

aggregate divergence. If we're focusing on 

quality as opposed to kind of just focusing on the 

final number and the Probability of Causation 

results that comes out of that. But if we're 

interested in kind of differences in quality 

between two evaluations, we might also want to look 

at something that integrates up the differences, 

like sum of squared differences.

CHAIR KOTELCHUCK: The differences 

between the --

(Simultaneous speaking.)

MEMBER RICHARDSON: Yes, at each of the 

intermediate steps of the calculation. So where 

we use the underestimates in some places and 

overestimates in other places, those are all 

disagreements and we could have something which 

would quantify that.

CHAIR KOTELCHUCK: That would be a good 
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idea. It will involve a fair amount of work. I 

was also going to suggest later on in the 

discussion, but since it's coming up now, just to 

say that it might be nice, when we finish these six 

blind cases, for the SC&A folks to look at the 

differences in the totals rather than the 

sub-parts, the differences in totals and the 

differences in PoCs for sort of summarizing the 

tables, that we see what, if you will, the average 

differences are. And what you're suggesting is 

something a little bit more -- a little finer, much 

finer.

MEMBER RICHARDSON: I mean, even it's 

at the internal dose, external dose and 

occupational, environmental, for each of those 

components, it shouldn't be that much work. 

You've got basically sets of numbers that are --

(Simultaneous speaking.)

CHAIR KOTELCHUCK: I think -- is it 

reasonable to do -- I mean, let's ask for our 

Committee Members and others --

MR. KATZ: Well, let me raise a 

question first.
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CHAIR KOTELCHUCK: Okay.

MR. KATZ: I think, until you have this 

discussion with the Subcommittee and NIOSH and 

SC&A, a discussion as to the differences, as we just 

did, you don't know which was actually correct. 

And like in this case, both of NIOSH's -- the 

differences, NIOSH was correct in what it applied. 

And so I'm not sure what you're gaining there by 

doing any kind of analysis on differences when one 

was correct and one was not. What are we learning 

from the difference between the incorrect method 

and the correct method?

CHAIR KOTELCHUCK: Well, let's say 

this: I have not viewed our past differences 

between the two as one was correct and one was not. 

I viewed them as two independent reviewers. You 

might argue here that one -- I mean, the 

justification that NIOSH gave for what it did made 

sense to me. But I would still not say that, well, 

overall we ought to accept what NIOSH did. And I 

think it's important that they were as close as they 

were on as many of the measurements that were done, 

or the assessments that were done.
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So, to me, I don't view this as, if you 

will, one group won the battle. It seems to me that 

they both did a good job and that I do accept, in 

many cases, that the NIOSH folks have a much clearer 

sense of what's going on in each facility than SC&A, 

in a sense due necessarily to NIOSH's task and 

ORAU's task. But I still think, to my mind, an 

assessment of the differences and a more detailed 

assessment of the differences between the two for 

what will now be I think 26 cases, I think is 

warranted. 

However, I don't think -- I'm 

personally not ready, just as one Member of the 

Committee, I'm not ready to suggest that we do that 

until we finish this set of six, which would be at 

the end of the next meeting.

MR. KATZ: Okay. I mean, that's fine. 

But there are clearly instances where there are 

errors on both sides, clear errors. And where

there are errors I'm not sure that you have what 

you're saying, which is two equal but different 

approaches. So, but that's fine. I mean, it's up 

to the Subcommittee how it wants to go forward on 
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this.

CHAIR KOTELCHUCK: Yeah, well, if 

there are errors on both sides, then the 

Subcommittee is failing in its job. I think we are 

looking at -- we're trying to check -- we're looking 

at and approving the work that was done. And the 

initial assumption certainly is that these are both 

equally valid independent assessments. And by the 

way, SC&A says that in the reports clearly we're 

not deciding who's right and who's wrong. 

MR. KATZ: Right, SC&A does not believe 

it's its position to do that. It's up to the 

Subcommittee to make judgments about that.

CHAIR KOTELCHUCK: Right. What do 

other Subcommittee Members think about this 

conversation Ted and I are having?

MEMBER MUNN: I'm so glad you asked. 

I've been biting my tongue. 

It might be instructive for us to go 

back to our original mission: why are we doing this? 

And if our reason for doing this is to gain more 

statistical information, then what we're 

discussing in terms of pursuing further the 
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differences that we do see in these things, then 

this discussion in my view is valid.

If, on the other hand, our purpose in 

doing this is different, then perhaps we are 

attempting to gild the lily to no good end. If our 

purpose in doing this is to ascertain that a group 

of trained scientists are performing the duties 

that are assigned to them within the parameters 

that we have established for them, then we're okay 

the way we are, simply because, as has been pointed 

out already, what we've seen is -- and what we 

intended to see, I think, is whether different 

approaches to the same information would give us 

a statistically significant difference in result. 

Because there's, as someone else has already 

pointed out, there isn't always an absolute right 

way and an absolute wrong way. There are several 

ways to approach a number of questions.

The question was, given the same 

information, are the assessments that are being 

made reasonable and can we expect them to continue 

to be reasonable based on what we know? If what 

we're seeing as a result of this is a severe failure 
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in accommodation of the rules we set up, then there 

is something to be gained by trying to identify how 

we can change that. 

But we have two groups of individuals, 

both highly trained in doing the specific things 

we're asking them to do. For the most part, 

there's no issue about how to interpret the 

information that's there. When there is some 

difference in interpretation, if it is something 

that we should be changing, then it's incumbent on 

us to try and identify what that is. But I don't 

see that that's the case here.

MEMBER CLAWSON: This is Brad. I had 

questions because we were in two different areas 

and we had two different things, and, you know, we 

came out fairly close. 

Dave, I know that you have been with 

this in the long run, but what I was trying to find 

out is what the difference is. I'm not as elegant 

a speaker as Wanda or anybody else. I always look 

at it like this: we've got two different ways to 

skin a cat, but we still got the cat skinned. But 

are there -- we can't say which one is right and 
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which one is wrong. And that's why I was wondering 

about the 30 years versus the 10 years.

But the way that NIOSH looked at it I 

thought was very good. And I think I truly believe 

that, in what we were trying to do, it had been 

accomplished here. I don't feel that we need to 

analyze it more. This is why I think we're here 

today, is to be able to go through these, get a 

better understanding, and if there is something 

that's reaching out and grabbing us that something 

isn't quite right, then it's up to us as a 

Subcommittee. 

I don't see that we would -- and I'm 

agreeing with Wanda, so don't anybody say or 

anything like that, but I don't think that we would 

gain anything from this. I think this is very good 

and I like the way that this is. You know, think 

about this: you've got two different people and one 

of them has been doing an awful lot for this one 

site and then we come in and we do it the same way, 

pretty close. We don't know all the nuances or 

anything else like that and we still come out this 

close. That, to me, I tip my hat to both sides. 
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This is really good and I think, my personal feeling 

is that I don't think that we gain anything more 

from this, Dave.

I just had questions and I wanted to 

clarify in my mind on how the approach is and how 

they were different. And I was satisfied with 

them. I think they both did a good job. 

CHAIR KOTELCHUCK: Well, it may be the 

statistician in me, but I feel like we have some 

really good data. Overall, I'm very pleased with 

the results that we've gotten so far with the blind 

dose reconstructions because they have been quite 

reasonably close to each other given the complexity 

of the calculations and the different assumptions 

that must be made in the absence of perfect 

measurement data in the field.

But I do think that we have our hands 

on something with these calculations comparing the 

two independent and well-qualified groups that we 

may be able to spot something where there is a 

difference such that we could improve our -- we can 

approve our assessment and our procedures going 

forward, and I don't want to throw it away. So, 
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and I'll tell you right now, when we get down to 

the third one here today, I have precisely that 

concern. But we'll talk about that when we get 

there. 

But basically I feel as if there is 

information to be gathered overall for our 

claimants. The fact that we come to similar 

conclusions with two independent studies is very 

important and very satisfying. And for the 

claimants, they should know that with all the 

different assumptions that are made and all the 

complexities two different groups come out the 

same, almost the same. And in particular, so far 

we have not had a situation where the two 

independent groups come out on different sides of 

the decision matrix of compensating or not 

compensating.

So that's very good, but I still think 

there are things to learn. And it may be -- I'm 

open when we get to it -- because we're not ready 

quite to make a decision. But when we get to it, 

we may want to form a little subcommittee. Not 

everybody wants to spend a lot of time on that. I 
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just feel like the information is there. I don't 

want to throw it away. That was my take.

MEMBER CLAWSON: Well, and we have a 

record of that. And you know what, Dave, there may 

be some that come up that are very intriguing. I 

never close my mind to learning and understanding 

this better. But the one thing that you did say 

is, you know, to the claimants, these have been 

blind, and so by looking at them as blinds I've been 

impressed that we've come out this good. Because 

we've been involved in setting up how the blind is 

going to be done. I already feel pretty good, but 

you know what, that being said, I'm not ever against 

keeping the information or whatever and how we go 

about it, but I feel pretty good about this one.

CHAIR KOTELCHUCK: Well, folks, is 

this -- unless there's further discussion, maybe 

we ought to accept this as a Subcommittee and move 

on. Does that sound reasonable, folks?

MEMBER CLAWSON: It is with me.

CHAIR KOTELCHUCK: Good. Good. 

Okay. Hearing no objection, we accept this, with 

thanks. And let's move onto the second one, which 
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is the Rocky Flats Plant blind case.

Rocky Flats

DR. BUCHANAN: Okay. This is Ron 

Buchanan. And if you'd pull that up, we'll start 

out on page 8. 

CHAIR KOTELCHUCK: Now, Ron, before we 

start on this one, could I ask, there were a number 

of typos in this paper, and I don't know whether 

you want me to wait until the end? Some of them 

are pretty obvious and other ones are slightly 

embarrassing, like the difference between prostate 

and prostrate, which appears a few places. And I 

think those are important enough to deal with.

Do you want me to wait until you're 

finished and then give you mine, or would you like 

me to just briefly interrupt? All I have to do, 

I think, is just point them out.

MR. KATZ: Or we could just send an 

email, Dave, and catch all these editings offline.

CHAIR KOTELCHUCK: Oh, you know, 

that's a good idea. Okay. So I will do that. 

I'll send those offline. But, I mean, there are 

always small typographical errors and it's no big 
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deal, but there were a few that came to my notice 

and were a little bit prominent. So I'll send 

that.

MEMBER MUNN: Always worth changing, 

David.

CHAIR KOTELCHUCK: Yeah. Okay. Very 

good. Well, let's, Ron, go ahead. I'm sorry. 

That's cleared up now.

DR. BUCHANAN: Okay. Thank you. 

Okay. We'll go back one page, Rose, to page -- or 

Table 1.1 on page 8. Yeah, there we go.

Okay. This was a Rocky Flats case for 

a worker that worked there in the late '60s, '70s, 

and '80s as a craftsman at this facility. And we 

see that Table 1.1 there contains the cancers. 

And, Rose, that first thing he's 

talking about a typo is the last word on cancer No. 

3 should be obviously -- it should be temple, not 

bladder. 

CHAIR KOTELCHUCK: Ah, very good. 

Thank you. Right. Now, if I may just, for a 

second, just so that I understand what's going on, 

the last line of text before Table 1.1, they're not 
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all three skin cancers. It says three skin cancers 

listed in Table 1.1.

DR. BUCHANAN: Yes. You're correct. 

That should not --

(Simultaneous speaking.)

CHAIR KOTELCHUCK: Okay. Good. 

Because that actually confused me for a while. 

Okay. So temple and we'll drop the skin in the one 

above.

DR. BUCHANAN: Right.

CHAIR KOTELCHUCK: Okay. Good. 

Good. Do go ahead again.

DR. BUCHANAN: Okay. So we see that 

SC&A and NIOSH -- and in this discussion I'll just 

talk about the two DRs instead of keep repeating 

that. Both DRs used the best estimate method and 

resulted in PoC less than 50 percent. So we had 

no major issues there. 

So if we go down to the next page, page 

9, on Table 1.2, it shows a comparison of the 

methods used and received at -- I won't go 

through -- well, not comparison of the method, 

comparison of the doses. And we see we had 
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recorded doses, both photon and neutron. We had 

missed dose, we had coworker dose, we had ambient 

dose, medical dose, and internal missed dose from 

plutonium, americium, DU and RU, and pure 

americium. And we came out with doses very much 

similar, in the 10 rem range. And both PoCs were

less than 50 percent and similar. 

And so if we go down to now page 10 on 

Table 2.1, and we see that we have a comparison 

table there. And we'll go over all the 

similarities. I'll just highlight the 

differences and then discuss those in more detail. 

For this dose reconstruction, most of 

the doses came out similar. The main difference 

was that NIOSH used the RFP, Rocky Flats Plant, 

calculational workbook. SC&A used the TDB-6 and 

did the hand calculations. They used Weibull. 

SC&A used normal and log-normal distribution, 

whereas NIOSH used Weibull, normal, and log-normal 

for recording the doses. And what this does is if 

you come up with the same dose but you put the 

distribution in, it'll be slightly different total 

doses the way they total the Weibull. 
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Missed doses, number of zeros, we 

counted 68. NIOSH used 71. And you might say, 

well, why just counting zeros is there a 

difference? Well, perhaps it's been discussed in 

the past, but I'll refresh your memory: It’s that 

this isn't clear-cut, this list of numbers that you 

look at for the number of zeros. You have to look 

at the badge exchange frequencies and also how they 

changed their accounting methods during the years. 

And so, you have to look at gaps. Was 

this a quarterly exchange? Did the person not 

exchange it and keep it for six months? Was it a 

yearly exchange? And then, do you fill that in 

with gaps? Do you fill it in with zero? Do you 

fill it in with coworker? So throughout this 

presentation we'll notice that there are slight 

differences mainly in how we address those gaps in 

the dosimetry records, whether we count them as 

zeros, get adjacent quarters to fill in a missing 

quarter, or do you count it as a worker dose.

We'll see the recorded neutrons are 

very similar. The missed neutrons, they counted 

75. SC&A counted 72. We see that on the coworker 
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dose the main difference there was a difference in 

the months. They counted 12; we counted 14. And 

they applied a 0.65 factor to the 1969 shallow dose 

and we did not because we didn't find that the TBD 

stated that.

And so, we'll go down to the next page 

and the tail end of that table. And we see that 

the main difference there is that when they used 

the uranium internal missed dose assignment, they 

use a Workbook ITIW and we use the older CADW to 

assign them. And so a slight difference there.

So we see that the main difference is how we counted 

zeros, coworkers, et cetera, and the dose 

distribution for this dose reconstruction.

So we want to start on the recorded 

dose. Down the page just a little bit there we see 

that the EE was monitored on a different basis 

throughout the work history. And so that's some 

gaps, but the recorded dose we're fairly well there 

most of the time. And so, NIOSH used the method 

of using the dose conversion factors to assign 

doses to the three cancer sites. 

And so we did also. NIOSH used a similar 
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dose. The only difference was Rocky Flats had a 

very complex method there in '69 and '70, which you 

have to go through some equations to determine what 

the shallow dose, the penetrating dose, and the 

total dose was -- and from [that] the total dose. 

And so, it kind of depends how you approach this 

and how you address it. 

We did go in and use the NDRP data which 

does sometimes give additional photon dose. And 

so we came out with very similar doses, but slightly 

different. And you see we summarize those in Table 

2-2 on down a little bit, and we see that they all 

ran similar, around 1 rem for all the organs, and 

also the less than 30 keV were similar doses also 

except that we used some of the different equations 

for '69 and '70 than they did, so it came out with 

slightly greater doses in the shallow dose.

Our next item is missed photon dose. 

Again, this is when the worker maybe wasn't badged. 

So we assigned a one-half LOD value. NIOSH counted 

71. We counted 68 over the period. And we're 

saying that we both assigned about 0.8 rem to each 

of the cancer sites. And the main difference was 
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the way we assigned the zero missed dose. And 

NIOSH also used the Weibull distribution for some 

years, which moderately changes some of the total 

dose calculated. NIOSH also used a range in the 

dose conversion factor while SC&A used constant 

modal values from IG-1. And so, they're close, but 

there's slightly different methods there.

So that brings us down to the recorded 

neutron dose. If you scroll down a little bit 

there. We see that Rocky Flats did have monitored 

neutron dose most of the time. But the doses, they 

weren't usable, so we used N over P values for '71 

through '76. And so they've assigned according to 

the dose conversion factors. They're given in 

Table 2-3. And we see that both NIOSH and SC&A used 

the same conversion factors. And they assigned 

about one rem of recorded neutron dose to each organ 

and so did SC&A.

Then we see that the main difference on 

the top of page 14 there is that NIOSH used some 

Weibull and logarithmic, log-normal distribution. 

And SC&A used just the log-normal distribution. 

And so that there were similar matches. The doses 
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were similar, very close, and the distributions 

were slightly different, but close. 

Let's move to the next section, which 

is missed neutron dose. And again, NIOSH added up 

75 badge exchanges with zero or less in LOD over 

two readings. SC&A counted 72. And there is an 

error there. If you go down to where it says NIOSH 

entered the missed neutron dose as in IREP with 

neutron energies of 100 percent [of] 30 to 250 keV, 

that's obviously incorrect. We entered it 

according to the Table 1 we just looked at. And 

so that "100 percent [of] 30 to 250 keV" should be 

removed.

Next paragraph shows that NIOSH 

assigned about one-and-a-half rem to each cancer 

site, and SC&A assigned a similar amount. The main 

difference was in the number of zeros and the 

distribution factors used and the dose conversion 

factors used. We used the same dose conversion 

factors that NIOSH used in Monte Carlo, so we had 

a range of dose conversion factors. SC&A used a 

constant modal value.

So now there were gaps in the record 
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for -- well, for '69 and '70, coworker dose was to 

be assigned for any zero readings where there 

weren't any dosimeter badges. Or sometimes during 

this period Rocky Flats had assigned zero even if 

the badge wasn't read. And so in that case, you 

should [use] coworker dose at Rocky Flats during 

'69 and '70.

And so it depends on what you counted 

as a badge cycle. NIOSH used three months for 

coworker dose necessary in '69 and nine in '70. 

SC&A counted 9.6 in '69 and 5.6 in '70. Did I say 

that? NIOSH used nine months in '69 and three 

months in '70. And we used a slightly greater 

number the way we calculated it. And NIOSH 

assigned slightly less than we did, and the 

difference was the way we calculated the coworker 

dose. 

Now, this was somewhat offset by the 

number of zeros. And so, in this case, usually 

pretty much it washes out, but we did the same thing 

on it, but used a slightly different interpretation 

of the data, the recorded dosimetry data.

Now, the shallow dose, this is where our 
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main difference was. We calculated the less than 

30 keV photons because it was a plutonium handling 

facility. So you assign less than 30 keV photons, 

just beta dose. And so we both assigned similar 

doses, except in calculating the 1969 dose NIOSH 

divided by the factor of 0.65, which came from the 

open and closed window, a difference of 0.35; 1 

minus 0.35 is 0.65. And those are covered in 

equations 3 through 6 of the Rocky Flats TBD-6.

And we did not find that they 

specifically said to apply that 0.65 factor to the 

coworker dose, so we did not. And so we came out 

with a slightly less dose than NIOSH did for the 

shallow dose for '69 and '70.

Now we want to go to the next page. 

It's the neutron coworker dose. Or not the next 

page, but down a little bit. We used the coworker 

to assign doses during the '69 and '70 period. 

Again, NIOSH assumed nine months for '69 and three 

months for '70. And we assigned 9.16 months for 

'69 and 5.67 months for '70. And so this would come 

out slightly different in the dose assigned. And 

those are summarized in the Table 2-4 there. 
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You'll see they're similar, but our doses are 

slightly larger because of the more months. We 

used slightly more months. 

Onsite ambient is the next subject. We 

see that according to TBD-4 -- or no, Procedure-60

actually-- that gives the details on this, that 

from prior to 1970 and after 1990 that Rocky Flats 

used to assign ambient dose because they subtracted 

that out of the badge readings. And so you need 

to add that back in. And so that was four millirem 

a year. And we see that we both assigned a total 

of several millirem there for the work period. And 

we both agreed and assigned the same dose, so 

there's no issue on that in this case.

Okay. We'll go to occupational 

medical dose here. We see that there are some 

records of X-rays. And there was a pre-hire AP and 

lateral scan. And we see that they used the TBD --

I mean, excuse me, OTIB-6 -- to assign doses to the 

organs, and we both assigned the same dose and had 

no issues with that. Okay. And assigned as a 

normal distribution of 30 percent uncertainty. We 

both did that. 
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So that brings us down to internal dose 

on the next page. We see that the worker had 

urinalysis in the '60s for uranium, americium, 

plutonium. And had whole body counts in the '60s, 

'70s and '80s. And all of the results were less 

than the minimum detectable activity or limits. 

And so what we did was assign missed plutonium, 

missed uranium, and then pure americium. 

So if we look at the plutonium, we both 

looked at the uranium -- I mean, excuse me, the 

urinalysis information -- and that they used 

one-half MDA in the IMBA program to back-project 

the intake. And also looked at the whole body 

counts for plutonium and decided which one would 

provide the most claimant-favorable or upper bound 

limits on the intakes. 

And so both dose reconstructions found 

that type M plutonium provided by the urinalysis 

would provide the best estimate dose. And we'll 

see that the next table there on page 18, Table 2-5, 

is a summary of that. You see that we had similar 

projections, very close to the amount of intake. 

And we used the Chronic Annual Dose Workbook, and 
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NIOSH used the ITIW Workbook, to assign the annual 

alpha doses to the organs. And we [see] down there 

at the Table 2-6 that the comparisons were very 

close for the missed uranium.

We can go to missed -- I mean, excuse 

me, missed plutonium. We go to missed uranium now. 

I was reading the next slide. NIOSH and SC&A both 

found that the EE was monitored for uranium intake, 

however, all less than MDA values. And so we go 

through the process of assigning missed uranium 

intake. 

Now, in this case, we assumed different 

pathways. NIOSH assumed 100 percent uranium 

exposure from U-234 and calculated, you know, used 

one-half MDA to back-calculate the intake and used 

the ITIW to assign dose of about around 50 millirems 

to each of the dose -- to each of the organs. 

Whereas SC&A assumed that exposure to DU as 

recommended in Section 52 and 56 of TBD-5. We used 

one-half the MDA and used that in the CADW to do 

the dose. But first we looked at the background 

level of the whole body counts to determine what 

that would project and found out -- compared that 
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to the urinalysis and found that the urinalysis is 

more claimant-favorable. So we used that data. 

And so we then used that in the CADW to 

do the dose calculations and came out about half 

a -- excuse me, about 50 millirems to each organ. 

So we used different paths, made different 

assumptions, used different methodology, but ended 

up with very similar doses.

We see that our last item on internal 

intake was americium. The worker did have 

americium analysis and it's less than the MDA. And 

so we assumed that this was probably for pure 

americium, working on the pure americium-241 

project, or around it. And so, both DRs assumed 

that and used -- NIOSH used their ITIW to assign 

dose of about 100 millirem to each of the organs. 

SC&A used the IMBA to do a projection of the intake 

and a CADW to estimate the dose. And again, around 

100 millirem to each organ. 

And very similar doses. A slight 

difference, the only thing I can see, we had very 

similar projections of intake, was the workbook 

used to assign the annual doses resulted in a 
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slightly different total dose.

We'll go to page 20 for incidents. 

Both DRs evaluated the documentation that was 

available, the CATI and the DOL, DOE records, and 

found no incidents that would really change the way 

the DR was done. The worker was monitored 

externally, internally over most of the period of 

employment and we did not find any incidents that 

would change our dose reconstruction methods.

So Section 3, Table 3-1 on the next 

page, summarizes our conclusions. And we see that 

the total doses assigned were around 10 rem to each 

organ. The PoC was less than 50 percent in both 

cases. 

And as I've discussed during this 

presentation that our main difference was the type 

of distribution used. The Weibull would result in 

slightly different total doses. And the method 

used to determine the shallow dose in '69 and '70 

and the coworker dose in '69 and '70 were slightly 

different. And the use of ITIW and CADW to assign 

annual doses result in slightly different dose 

distributions.
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 And let's see, there is a correction on 

that page. Let's see, on page 21. If you go down, 

it says assignment of coworker shallow photon dose. 

Down at the last sentence of page 21. NIOSH 

identified 9 months of photon exposure in requiring 

coworker dose for 1969 while SC&A required --

assumed 9.61 months in '69 and 2 months for '70. 

Okay. The part where it says, "While SC&A assumed 

9.61 months for 1969," that should be deleted 

because we're still referring to NIOSH's 9 months 

and 3 months. 

And so the next page then tells what 

SC&A assumed. So that's an area we need to 

address.

MS. GOGLIOTTI: Okay. Ron, I'll take 

note of it and we'll correct it.

DR. BUCHANAN: Yeah, okay. And so, 

like I say, the main differences were assuming 

zeros, coworker months, gaps and the distribution 

factors. So [these] were our main differences. 

So that's open for questions now.

(Pause.)

MEMBER MUNN: Did I lose you?
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MR. KATZ: No, no, no. You're on. 

You're on.

DR. BUCHANAN: No, I'm done. If there 

are any questions. I'm done.

MEMBER MUNN: I interpreted that Ron 

was saying he was done.

MR. KATZ: Is Dave still on?

MEMBER MUNN: But I didn't hear anyone 

else saying anything.

MR. KATZ: Yeah, I'm not hearing Dave. 

Is Dave on? I'm worried we might have lost Dave 

Kotelchuck, but --

MEMBER MUNN: Oh, dear. I hope not.

MR. KATZ: Either that or, Dave, we 

can't hear you if you -- maybe you're on mute. I 

don't have an email from him, so I don't have any --

CHAIR KOTELCHUCK: You're right, I was 

on mute. I'm sorry.

MR. KATZ: Oh, okay.

CHAIR KOTELCHUCK: And that's why 

there was silence. I spoke right after he finished 

and I said it was a very nice presentation and the 

results were quite similar. And, good. But I was 
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hoping to hear comments.

Wanda, were you about to say something?

MEMBER MUNN: No, I wasn't. I was just 

waiting for any other --

CHAIR KOTELCHUCK: Right. Okay. 

(Laughter.)

CHAIR KOTELCHUCK: Alright. You're 

right, we had some noise out on the streets here 

in New York and I --

MEMBER MUNN: How odd.

(Laughter.)

CHAIR KOTELCHUCK: Right. So I hit 

the mute and forgot to that I was on mute.

MR. SIEBERT: This is Scott. If you 

want to a couple of clarifications, I'd be happy 

to add just a small couple things.

CHAIR KOTELCHUCK: Sure.

MR. SIEBERT: Number one, with the 

number of zeros being counted, Ron is exactly 

correct. At Rocky Flats it's extremely 

complicated to determine the number of zeros based 

on the timeframes that people are monitored as well 

as dealing with the NDRP data and then putting that 
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all together. So the fact that those numbers are 

very close to each other, I was very heartened to 

see that. That's good. 

There's also some slight differences 

based on the fact that we use the best estimate 

method that's outlined in OTIB-1 and Procedure-6, 

that there's some averaging and so on. So that's 

how there's times, if you notice, in comparison 

we'll have a number like 6.5 zeros, which sounds 

really odd, but when you do an averaging 

methodology as outlined in that document, that's 

why you'll see some of those differences. So that 

was good. 

The other thing I just want to point out 

is people may have been hearing about something 

they haven't heard before, and I want to clarify. 

The ITIW tool, all that is is a workbook we can use 

to take results that we ran in IMBA to get doses 

and put it in a format that is an IREP format easily 

put into IREP. The reason it's called that it's 

ITIW is it's IMBA To IREP Workbook.

So every time they're talking about us 

using that tool versus them using CAD, what really 
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happened is, because we are in best estimate 

territory, we ran the doses through IMBA so we 

weren't doing the overestimating assumptions that 

were in CADW. So that's why there's going to be 

some slight differences on the internal doses as 

well.

MEMBER MUNN: That does help. Thank 

you. At the time that I read it I thought I don't 

really know about this, but then there are many 

workbooks that we're not familiar with, at least 

I'm certainly not.

MR. SIEBERT: And we do love our 

acronyms, don't we?

MEMBER MUNN: Oh, yes, we do. 

Especially the TLA from the SLAs.

CHAIR KOTELCHUCK: Very good. Okay. 

Other comments?

(No response.)

CHAIR KOTELCHUCK: I will say it's --

I have some discomfort looking on -- just like on 

that summary Table 1.2 that the total doses for each 

of the three cancers are higher for SC&A by 0.3 to 

0.5 rem, and yet the PoC is smaller, right? So 
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you'll have -- SC&A has higher doses but smaller 

PoC. And I assume; and correct me if I'm wrong --

no -- rather not correct me, tell me was it 

primarily the fact that some different 

distributions were used?

MR. SIEBERT: Yes, I would say the 

differences are, yes, number one, the distribution 

for especially the external dose based on these 

best estimate processes in Monte Carlo. And as 

well, there's -- as I mentioned before, there's --

they assigned slightly more internal dose than we 

did. That's why their numbers are slightly 

higher. 

CHAIR KOTELCHUCK: Yes.

MR. SIEBERT: But the distributions 

out there, those are going to be pretty close to 

the same, so it's mostly going to be 

distribution-related.

CHAIR KOTELCHUCK: Yes. I'm worried. 

Looking from the outside it looks -- it is 

disturbing, right? And maybe it's the story of a 

little knowledge is a dangerous thing. But you 

have higher dose and smaller probability of getting 
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cancer on the job. But what that just really tells 

us, the kinds of spreads that are put in between 

PoCs as we use different distributions. 

On the other hand, the PoCs are clearly 

close together. I mean, they are -- and they're 

on the same side of compensation with NIOSH's being 

a little higher, which is fine.

MR. SIEBERT: This is Scott. I was 

guessing -- when you mentioned the Fernald case, 

which we'll get to -- 

CHAIR KOTELCHUCK: Right.

MR. SIEBERT: -- I'm guessing that is 

also your question on that one.

CHAIR KOTELCHUCK: Pardon?

MR. SIEBERT: I was guessing that's 

probably also your question on that one. It's 

probably going to the same answer.

CHAIR KOTELCHUCK: And that's 

interesting. Okay. Well, we will do that because 

that one there we had a much bigger difference in 

PoC than we've had in many of the others, and it's 

important to understand why. Yes, but may well be. 

May well be. Anyhow -- 
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MEMBER MUNN: Dave, from one 

perspective though that's very good. If you're 

looking at the perspective of some that we have 

adopted, that we're going to use the most 

claimant-favorable methods for doing what we do. 

Then the fact that the end results are so near, but 

that slightly different approaches still put you 

in the right ballpark and that the ones that are 

being used by NIOSH create a slightly larger 

percentage seems to me to be good from a claimant 

point of view.

CHAIR KOTELCHUCK: I agree. I agree. 

And overall the blinds are -- I think are 

reassuring --

MEMBER MUNN: I agree.

CHAIR KOTELCHUCK: -- to the claimant 

population, that things are not determined by the 

fact that a particular reconstructor is -- makes 

poor choices or better choices, but that it doesn't 

really matter terribly. And the PoCs are about the 

same and certainly the decisions are the same.

Folks, any other comments or shall we 

accept this as a Subcommittee?
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MEMBER MUNN: Yes.

CHAIR KOTELCHUCK: Okay. Any 

objections, concerns? 

(No response.)

CHAIR KOTELCHUCK: Okay. Then that is 

accepted.

Now it is almost noon. We have one last 

blind to do today, the FMCP. What do people think? 

I mean, I'm -- we might -- since we talked to the 

other people about doing the -- coming in at around 

1:30 after lunch, I'm happy to go another half an 

hour and see how far we get on the other. Hopefully 

we might complete it. Would others be willing to 

go onto the third one now for another half an hour?

MEMBER MUNN: That's fine here.

CHAIR KOTELCHUCK: Okay. Anybody 

else?

(No response.)

CHAIR KOTELCHUCK: Okay. Then let's 

go ahead to the FMCP blind.

Fernald FMCP

MS. K. BEHLING: Okay. And this is 

Kathy Behling. This is a Fernald case and I'll 
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have Rose go to page 7 and we can look to see that 

there were two cancers associated with this 

particular case. And that is shown on Table 1-1. 

Here we go.

CHAIR KOTELCHUCK: Yes.

MS. K. BEHLING: And in this particular 

case both SC&A and NIOSH calculated doses that were 

similar and came to PoCs that were less than 50 

percent. And so if we go onto page 8 on Table 1-2, 

we have the comparison of the doses. And as you 

can see, the external doses are all nearly the same. 

The environmental dose for SC&A is slightly higher, 

just minor difference and a difference in the 

energy distribution, which I'll talk about later.

Also there is some difference in the 

internal dose. Again, in this case SC&A's dose is 

slightly lower. We'll discuss that. And as was 

mentioned, even though the doses were very similar, 

there is some difference in the PoCs which I will 

get to when we get to the -- near the end of this 

discussion. But as we said, both methods came in 

less than 50 percent. 

So if we move on to page 9, this 
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individual was monitored -- was actually employed 

a very short period of time, slightly less than one 

year, but the individual was monitored for external 

and internal exposures. And if we go to Table 2.1, 

here's the comparisons that we put together. And 

pretty similar. And I'll get into details. A 

little bit of difference in the missed photon dose 

associated with DCFs that were selected. Also 

dose distributions for the coworker, the 

unmonitored photon doses.

Onsite ambient dose. If we go to the 

next page, there was some difference in the energy 

fractions that were selected and also the DCFs that 

were selected. If we go on to internal, here I'll 

get into that in more detail. The difference had 

to do with the selection of percentage of the 

uranium intake. Then finally, the results. So 

some difference in the method used for the 

timeframe associated with the environmental 

internal doses. 

But if we move on, the individual was --

they were monitored for a brief period of time, but 

all the monitoring results were zero, therefore 
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they were treated as missed doses. And both NIOSH 

and SC&A assumed five zero badge exchanges. And 

those also assumed 40 percent energy fraction of 

30-250 keV and 60 percent of greater than 250.

If we move on to page 11, for the first 

cancer, both SC&A and NIOSH used the exposure to 

dose Hp10 DCF from the IG-1 guidance. For the 

second cancer, NIOSH went into Table 4-1A and 

selected the isotropic geometry, and that resulted 

in NIOSH and SC&A coming to different conclusions 

on the DCFs that should be used because, for the 

second cancer, SC&A actually looked at Table 4-2 

and assumed -- based on the job category assumed 

that information from 4-2 indicated that the likely 

geometry would be AP. And so therefore they used 

AP DCF. And so that resulted in some difference, 

but in actuality when it came to final doses, the 

doses were nearly identical, one millirem 

difference on the first cancer.

If we go on, there was also another 

brief period of time where there was no monitoring. 

Both NIOSH and SC&A used a coworker model and they 

used the 50 percent coworker model to calculate the 
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doses. They had a slight difference in approach 

for calculating the fractional year, but both --

like I said, both did assign a 50 percent coworker. 

The only difference was in the dose distribution. 

Let's see here. Okay. NIOSH entered this dose 

into IREP using a triangular dose distribution 

where SC&A entered it as a log-normal distribution 

with a GSD of 1.52.

If we go on then to onsite ambient dose, 

even though the individual was either assigned 

missed or coworker dose, according to PROC-60 it 

states that you also assign an onsite ambient dose 

after 1985. So both SC&A and NIOSH selected site 

average external doses from Table 4.3 for the 

Fernald TBD.

Now NIOSH used a triangular isotropic 

exposure geometry which was applied for the 

triangular distribution. And hold on one second. 

My computer is going to go blank on me here. Okay. 

Didn't want to lose my screen. Excuse me.

They -- as I said, NIOSH used the 

triangular distribution for the isotropic exposure 

geometry and applied it as a Monte Carlo, which 
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resulted in the data being entered into IREP as a 

Weibull distribution. And SC&A used the exposure 

geometry of AP -- an AP geometry and the DCFs were 

entered as a mode of the distribution. And it was 

entered into the IREP as a normal distribution with 

a 30 percent uncertainty. Again that resulted in 

a slightly higher dose is assigned by SC&A for the 

external onsite ambient dose.

Medical doses. Both methods used the 

records and there was one new-hire PA chest X-ray 

done. Both methods assumed the same -- assumed 

just one chest X-ray, used the same procedure, the 

TBD associated with Fernald, and came to the exact 

same result. And both methods also entered that 

data into IREP in the same manner, as a 30-250 keV 

with normal distribution and a 30 percent 

uncertainty. 

Now when we come to internal doses, the 

individual was monitored for internal uranium via 

urinalyses, but because it's such a short 

timeframe, it results in a large overestimate of 

the intake rates, therefore both methods used what 

was available at the time, which was OTIB-78, which 
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is the internal coworker model. I think that is 

no longer -- OTIB-78 has now been incorporated into 

Fernald's internal TBD, so that's no longer 

available, or no longer being used.

Okay. Is everyone still there? Can 

you hear me?

CHAIR KOTELCHUCK: Yes.

MEMBER CLAWSON: I can hear you, Kathy.

MS. K. BEHLING: Okay. I'm sorry. I 

just heard something.

MR. CALHOUN: This is Grady. Can 

anybody hear me?

CHAIR KOTELCHUCK: Yes, Grady.

MR. CALHOUN: Yes, I just got an 

announcement said mute off.

CHAIR KOTELCHUCK: I can hear you, 

Grady.

MR. CALHOUN: I've been sitting at this 

phone since the beginning.

MR. KATZ: So, Grady, that's my -- my 

theory was that the operator somehow muted you. 

Maybe you muted -- she muted everything coming from 

your house. I don't know.
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MR. CALHOUN: Well, it's actually the 

office and Beth is on.

MR. KATZ: Oh.

MR. CALHOUN: What's weird is my cell 

phone wouldn't even work.

MR. KATZ: Yes, I know. You said that.

MR. CALHOUN: So I'm on. 

MEMBER BEACH: And this is Josie. 

Yes, I've been trying to talk, too, and nobody could 

hear me, so I was wondering what was going on.

CHAIR KOTELCHUCK: I noted that you as 

a Subcommittee Member have been silent. So was 

Grady.

MEMBER BEACH: Well, I kept trying to 

talk.

CHAIR KOTELCHUCK: I wondered, but I'm 

glad to hear that you aren't silent, but that your 

technology silenced you.

(Laughter.)

CHAIR KOTELCHUCK: Welcome back.

MEMBER MUNN: They were in the famous 

cone of silence.

CHAIR KOTELCHUCK: Yes. Alright. 
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Thank you, folks. 

Do go on.

MR. KATZ: Yes, sorry, Kathy.

MS. K. BEHLING: That's alright. I 

wanted to be sure everyone could hear me because 

I heard the same announcement.

CHAIR KOTELCHUCK: Right.

MS. K. BEHLING: Okay. We'll move on 

with the internal. As I indicated, both methods 

did use the coworker model in OTIB-78. And those 

selected a 50th percentile uranium and compared all 

the various solubility types: F, M and S from the 

Tables 5-1, 1, 5-2 and 5-3. And type S solubility 

was the most claimant-favorable for both. Both 

methods assumed that.

According to OTIB-78 they use a 

specific activity of a two percent enriched 

uranium. Now NIOSH assumed that the uranium 

represented 100 percent of uranium-234, which is 

a conservative assumption, where SC&A used the 

activity fractions identified in OTIB-78, which 

indicate 76.9 percent of uranium-234, 2.68 percent 

of uranium-235, and 20.4 percent of uranium-238.
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The other thing I'll mention is that 

when NIOSH initially did their dose 

reconstruction, they were working with, I think Rev 

1 -- oh, Rev 2 of OTIB-78. And when SC&A did this 

dose reconstruction, the Rev 3 was out, and that 

resulted in a slight increase in the values, 

uranium values in Tables 5-1, 5-2 and 5-3. Both 

methods also considered intake from recycled 

uranium, and so they calculated doses for 

plutonium-239, neptunium-237 and technetium-99. 

The biggest difference here -- and you 

can see the doses were similar, but the biggest 

difference was NIOSH entered their data as 

log-normal distributions with a GSD of 3, and SC&A 

entered these values. And this was 63 rem, so it 

represented the majority of the dose for this case 

and not -- that was entered into IREP as a GSD of 

two. So that is what resulted -- and I'm jumping 

ahead a little bit here, but that is what resulted 

in the difference of a PoC of 48 percent assigned 

by NIOSH and 40 percent assigned by SC&A, even 

though the doses were very similar.

And lastly, both methods assigned an 
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environmental internal dose, and they based that 

on maximum annual intakes from the Fernald TBD-4. 

The difference in dose here, SC&A's dose is 

slightly less because NIOSH assumed that dose for 

a full one-year period and SC&A used the actual 

number of months to assign that, which would have 

been 9.5 months. So that resulted in SC&A's 

environmental dose being slightly less than NIOSH.

And if we go to the summary table on page 

15, again doses pretty similar, approaches 

similar, a little bit of difference in energy 

fractions and DCFs based on geometries assigned. 

But as I indicated, the big difference in the PoCs 

is -- was due to the GSD of two entered by SC&A for 

the uranium doses and GSD of three entered by NIOSH.

So does anyone have any questions?

CHAIR KOTELCHUCK: Dave. How would 

you determine -- how was the decision on the 

geometric standard deviation chosen and on what 

basis did you choose that? I know often it does 

seem that one seems to choose it out of general 

practice, but anyway.

MS. K. BEHLING: Okay. Quite honestly 
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the TBD specifies that the GSD should be a minimum 

of three. And so from my perspective NIOSH was 

correct by applying the GSD of three and SC&A should 

have also applied that.

CHAIR KOTELCHUCK: Aha. Okay. 

MS. K. BEHLING: Now I will ask if 

SC&A -- if the author of the dose reconstruction 

had a reason for doing a GSD of two that I'm not 

aware of, they may speak up. 

DR. BUCHANAN: Okay. This is Ron. 

Okay. I haven't looked at this case for a while, 

but I see on page 14 it's stated there that OTIB-78, 

page 12 said use a log-normal distribution with 

uncertainty of two.

MS. K. BEHLING: Okay. And the reason 

that I didn't pick that up; and I apologize, is 

because OTIB-78 is no longer being used and I went 

to the TBD, which does specify a GSD of three. So 

I should have gone back to the OTIB-78 to determine 

if that is what was said. And if that's what you're 

telling me, then I guess that would correct for the 

guidance at the time.

MR. SIEBERT: Well, this is Scott. 
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That version -- I believe that's incorrect. I 

believe it's always stated three.

DR. BUCHANAN: Hang on. Let me check 

here real quick.

CHAIR KOTELCHUCK: Sure.

DR. BUCHANAN: Could have been an 

error.

CHAIR KOTELCHUCK: Sure.

MS. K. BEHLING: And as I said, I --

because this is -- the OTIB-78 is no longer being 

used. It wasn't available on the web site. I 

could have gone into -- and I just didn't do that, 

because when I looked at -- everything has been --

that was in 78 has now been incorporated into the 

TBD-5, the internal, the Fernald internal dose 

TBD --

CHAIR KOTELCHUCK: Yes.

MS. K. BEHLING: -- and it specifically 

does say in there to use the GSD of three. 

MR. KATZ: It's okay, Kathy. That's 

what these discussions are for, to hunt down the 

reasons. So no worries. 

CHAIR KOTELCHUCK: Exactly.
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MEMBER CLAWSON: Kathy, this is Brad. 

I have a question, though. You know that we've got 

a new internal that has come out for Fernald, 

correct?

MS. K. BEHLING: I am looking at 

Revision 2.

MR. KATZ: Yes, Kathy may not be aware 

because it just came out, but --

MEMBER CLAWSON: Yes, it just came out. 

I was just wondering if --

MS. K. BEHLING: Okay. I --

MEMBER CLAWSON: -- you knew that part 

of it's going to change. I was wondering for my 

own personal interest of dealing with Fernald of 

how this is going to change stuff.

MS. K. BEHLING: Well --

MEMBER CLAWSON: I'll talk to you about 

it in a month or two.

(Laughter.)

MS. K. BEHLING: Okay. But generally 

the GSDs are, as a minimum, three. That's what --

in most cases, I believe. So I have to admit that 

I was a little surprised that SC&A did use two.
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MS. BRACKETT: This is Elizabeth 

Brackett. We've always had a minimum of three for 

the GSD for the coworker studies. There is a step 

where we look at -- we calculate the GSD based on 

ratios of the difference in 84th percentiles, and 

if it's less than 3, then the final value was set 

at 3. So I can't find a copy of OTIB-78 at the 

moment, but possibly the preliminary table was 

being looked at before the final table that was set 

at two, three because it had come out less than 

three.

DR. BUCHANAN: Well, I was looking on 

page 12 of 78 of Revision 3, 8/19 of 2015. It says, 

select a log-normal distribution in IREP with the 

calculated dose entered in parameter one and the 

associated GSD as parameter two.

MS. BRACKETT: Oh, that just means --

(Simultaneous speaking.)

DR. BUCHANAN: That was parameter.

MS. BRACKETT: Right, that's a 

column --

(Simultaneous speaking.)

DR. BUCHANAN: Yes, okay. I see. 
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Yes.

MR. SIEBERT: Ron, if you look at the 

table that's right there --

DR. BUCHANAN: Yes, it says three. 

Yes.

MR. SIEBERT: -- you've got -- defines 

the, yes, the GSD.

DR. BUCHANAN: Yes, okay. Yes, you're 

correct. I read that statement incorrectly.

CHAIR KOTELCHUCK: Aha. Now if this 

is -- and this is very helpful. If this is in 

fact -- if there was an error, then it seems to me 

that -- well, I was about to say you should 

recalculate it, but this is a blind test and errors 

are human. So maybe that -- but in this case there 

is a clear error.

MS. K. BEHLING: There is an error.

CHAIR KOTELCHUCK: Okay.

MS. K. BEHLING: And the other thing I 

will mention is we do our blinds and put out the 

results to you all and we tell you this is our dose 

and this is our PoC.

CHAIR KOTELCHUCK: Right.
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MS. K. BEHLING: So when I get the data 

to do the comparison, I don't feel -- and correct 

me if I'm wrong here, I don't feel that it's 

appropriate if I find an error like this to point 

that out at this point and say we're going to go 

in now and change our PoC. I'm afraid that that 

might look odd or -- 

CHAIR KOTELCHUCK: It would be, yes.

MR. KATZ: You're 100 percent right, 

Kathy.

CHAIR KOTELCHUCK: Correct. And even 

though there was an error made in this case, and 

errors are made in all dose -- in the dose 

reconstruction process, errors are made and we hope 

they're very small in number and very few in number. 

But you're right, you don't change it. And that 

is the way. And in fact I was about to enter into 

an area of error by saying, “Oh, you made a mistake. 

Why don't you recalculate and let's see what it 

really looks like.” And the answer is this is what 

it really looks like as it stands. 

MS. K. BEHLING: Right.

CHAIR KOTELCHUCK: But I'm glad we -- 
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I mean, I'm very glad that this allows us to see 

where an error was made and -- 

MS. K. BEHLING: And I guess -- excuse 

me. I don't mean to interrupt you.

CHAIR KOTELCHUCK: Go ahead. No, 

please do.

MS. K. BEHLING: I guess what it also 

points out is it does also show you the importance 

of the GSD and these distributions and what kind 

of an impact that that will have even when the doses 

are similar. So it points something out. I think 

this is -- 

(Simultaneous speaking.)

CHAIR KOTELCHUCK: Most certainly. 

Most certainly and usefully. And if and when we 

do some calculations about the differences between 

the I believe the 26 blinds, I'm not sure exactly 

26. -- this may be in fact outside of the -- this

may be the tail end of that distribution and 

statistically significantly different in terms of 

what the percentages are. 

So, comments by other Subcommittee 

Members?
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MEMBER MUNN: I think much more 

importantly than any of the numerical issues 

involved is that this particular exercise we've 

just seen demonstrates the ethical standard of our 

contractor. I don't think you can ask for more 

than that.

CHAIR KOTELCHUCK: Well, that's 

certainly true. 

So are other -- I have a question about 

something earlier. Early on when you were doing 

this, Kathy, you mentioned that the person spent --

in the first couple of pages -- I'm trying to find 

it. Yes, on page 9 you say an Energy employee who 

worked at FMCP for slightly less than a year. Now 

the person -- I looked at the appendix. I mean, 

the person worked and was getting measurements made 

between '93 and '08, 15 years. And I wondered why 

you said worked for a year. And they certainly did 

not get 60 rems in a year. So I don't understand 

what that sentence was about, the first sentence 

in 2.0, Comparison Methodology.

MS. K. BEHLING: Okay. And where are 

we talking about that?
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CHAIR KOTELCHUCK: At the -- in the 

text on page 9, 2.0, Comparison Methodology, the 

very first line says --

MS. K. BEHLING: Right.

CHAIR KOTELCHUCK: -- this case 

represents an EE who worked for slightly less than 

one year. Now that may be a true statement, but 

obviously they also worked either at that site or 

another site for many years before. Excuse me, for 

many years after. That sounds like the person's 

first year of work in fact from my notes. If you 

go to Appendix A, you can see measurements have been 

made over 15 years.

MR. SIEBERT: Well, it does --

MS. K. BEHLING: Go ahead, Scott.

MR. SIEBERT: Yes, this is just a 

clarification. Yes, the employee worked from --

those dates are correct. They worked for less than 

a year at the site. What you're probably looking 

at is the fact that the internal dose continues to 

be assigned after the intake occurs through the 

date of diagnosis.

MS. K. BEHLING: Date of diagnosis, 
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exactly. 

CHAIR KOTELCHUCK: Ah.

MS. K. BEHLING: The diagnosis for the 

first cancer was 2012 and the second cancer was -- 

oh, no, I'm sorry. 2011 for the first cancer and 

2012 for the second cancer. So obviously the doses 

will go -- 

CHAIR KOTELCHUCK: I see. Alright. 

That explains it. And that is 250 -- yes -- 

MS. K. BEHLING: Yes.

CHAIR KOTELCHUCK: -- that's 250 days, 

not much -- it's less than a full year, from May 

3rd to April 20th. No. No, no. No, no, no. 

That's -- I'm sorry. That is about a year, that 

is 250 days, work days. Okay. So my question is 

answered.

Any other questions, folks?

MEMBER MUNN: None here.

MEMBER CLAWSON: This is Brad. I'm 

good.

CHAIR KOTELCHUCK: Good. Good.

MEMBER BEACH: None here either.

CHAIR KOTELCHUCK: Good. And this was 
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a -- both the first and last discussions were very 

useful in my opinion, and [I’m] very glad we had 

them.

So I -- we're ready to close on this and 

Subcommittee approves. Any objections?

MEMBER MUNN: None.

CHAIR KOTELCHUCK: Okay. Good. 

And -- 

MS. K. BEHLING: Dr. Kotelchuck, can 

I -- if we're finished with this last blind, I would 

just -- when you're done with that, I'd like to ask 

one question before we go to break.

CHAIR KOTELCHUCK: Absolutely. Go 

ahead.

MS. K. BEHLING: Okay. I just wanted 

to remind you that -- and I'm not even sure how I 

remember this, but back in January of this year, 

I had sent you a memo regarding one of the blinds 

that was done very early on, I think in the 17th 

set. And that was the Allied Chemical and Dye 

Corporation that we had a great deal of discussion 

on.

CHAIR KOTELCHUCK: We certainly did.
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MS. K. BEHLING: And a lot of that 

discussion centered around the surrogate data 

issue. And you had asked me during one of the 

meetings to provide you with this memo that just 

recapped what we have done on that particular case, 

and it was -- and I did send a memo out, like I said, 

on -- it was January 10th, 2017.

CHAIR KOTELCHUCK: What date, ma'am? 

Excuse me?

MS. K. BEHLING: Yes, January 10th, 

2017. And if you'd like, I can forward this to you 

again. 

CHAIR KOTELCHUCK: Yes, please do.

MS. K. BEHLING: But -- okay.

CHAIR KOTELCHUCK: I don't remember 

it.

MS. K. BEHLING: Okay. And obviously 

it's been a while, but we can -- what I think the 

bottom line on this was is there was some discussion 

as to whether this Allied Chemical case should be 

sent on to the Surrogate Data Work Group, because 

I think that --

MR. KATZ: Kathy.
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MS. K. BEHLING: Yes?

MS. K. BEHLING: This is Ted. I mean, 

that was already done. We did that actually before 

even Christmas, but -- 

MS. K. BEHLING: Oh, really?

MR. KATZ: So -- yes. Anyway, that's 

sitting with the Surrogate Data Work Group. And 

the Surrogate Data Work Group then wanted some more 

information from NIOSH, which it has received. 

And that's on the plate for Dr. Melius to set up 

a Work Group meeting.

MS. K. BEHLING: Okay.

MR. KATZ: But that's all good and 

ready including I think your materials. But go 

ahead and send them again just so I can make sure 

that the Work Group got everything it should have 

gotten. But I'm pretty sure it included your 

material that you're talking about from January, 

Kathy.

MS. K. BEHLING: Okay. And, yes, all 

I was trying to do was lay out a timeline as to what 

I -- I was not aware that that case did get sent, 

and I just wanted to verify that.
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MR. KATZ: It did. Yes, it did.

MS. K. BEHLING: Okay.

CHAIR KOTELCHUCK: And what was -- to 

whom was it sent, by the way?

MR. KATZ: I'm sorry. So this was a 

case where -- 

CHAIR KOTELCHUCK: I remember the 

case.

MR. KATZ: Right. The Subcommittee 

basically was done with it.

CHAIR KOTELCHUCK: Right. Okay.

MR. KATZ: But the surrogate -- but Dr. 

Melius wanted to look at the surrogate data issue 

specifically for that case and explore that a 

little further with that Work Group.

CHAIR KOTELCHUCK: Excellent.

MR. KATZ: So that's what we've sort 

of -- 

CHAIR KOTELCHUCK: It's the Surrogate 

Data Work Group?

MR. KATZ: Exactly. Which I think -- 

(Simultaneous speaking.)

CHAIR KOTELCHUCK: Yes, good.
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MR. KATZ: But anyway, that's what 

happened there.

MS. K. BEHLING: Okay. 

CHAIR KOTELCHUCK: Well, good.

MS. K. BEHLING: Yes, very good. 

Thank you. I'm sorry.

CHAIR KOTELCHUCK: Good. No, I'm 

glad -- no reason to be sorry. Glad you raised 

this. So it is now almost 12:30 and 

so we're right on schedule. We will come back at 

1:30, say, and we'll start with the -- it was the 

AWE, I believe, was what you wanted to started with.

Okay. So, folks, thanks very much for 

a productive morning. And we'll return in one 

hour. 

(Whereupon, the above-entitled matter 

went off the record at 12:27 p.m. and resumed at 

1:38 p.m.)

MR. KATZ: I think we're ready for the 

AWE discussions.
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Category 1 and 2 cases from Sets 19-21

including cases covering Oak Ridge, the Gaseous

Diffusion Plants, Savannah River Site, Hanford, AWE 

sites and Other DCAS sites from Sets 14-18

CHAIR KOTELCHUCK: Actually, we're 

going to start with the four-eighty -- she was 

asking that we start with the --

MR. KATZ: Oh, yes. Okay.

CHAIR KOTELCHUCK: -- 482.

MR. KATZ: Four-eighty-two, right. 

Right. 

MS. GOGLIOTTI: Yes, and Joe, were you 

able to get through all of this? 

(No response.)

MS. GOGLIOTTI: If you're on the line 

and can hear us, press *6.

MR. STIVER: I just got an email from 

Joe that he is online, but he was needed, so --

MR. ZLOTNICKI: This is Joe Zlotnicki. 

Can you hear me?

MR. KATZ: Yes.

MS. GOGLIOTTI: Thanks.

MR. ZLOTNICKI: Yes, I was on double 

mute.

MS. GOGLIOTTI: Sorry about that. I 
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don't know what happened.

CHAIR KOTELCHUCK: Okay.

MS. GOGLIOTTI: So we're going to start 

with 482.1. We asked Joe to call in. This is why 

we're going a little out of order here. And this 

is a Hanford and Lawrence Livermore National Lab 

case, but the actual issue is surrounding Hanford.

And, Bob, actually I'll let you take it 

from here.

MR. BARTON: Sure. Thank you, Rose. 

Everybody can hear me now, right?

CHAIR KOTELCHUCK: Yes.

MS. GOGLIOTTI: Yes.

MR. BARTON: Okay. Great.

Okay. So this is a case in which, based 

on a facility that the EE worked in, there was a 

potential for exposure to what we're calling 

low-energy photons. That's photons less than 30 

keV. And what was done in the original dose 

reconstruction was to say because of that sort of 

unique exposure term, if you had open windows, 

which is generally considered the beta 

measurement, it wasn't going to be considered [as] 
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electrons. It was actually going to be considered 

to be low-energy photons. 

And what we noticed during the audit was 

that these were being applied up until about 1957. 

Specifically we were looking at the missed doses, 

and from 1957 to 1971 there was no application of 

that dose component. And then again in 1972 it 

picked back up again. So that's sort of what 

necessitated the finding. 

And we have a response from NIOSH. 

Unfortunately we brought it up at the last meeting, 

but we weren't able to open it, or at least I was 

not able to open it up for that meeting. We've 

since gotten the file. It's a two-page file with 

a couple of tables in it. And it's a pretty complex 

issue with -- which is why we have to bring in our 

sort of external dosimetric expert, Joe Zlotnicki.

And thank you for calling in, Joe.

But before getting started, I think it 

would be helpful to have NIOSH or I guess whoever 

owns this response to sort of walk us through why --

I think I understand why, but I don't want to get 

it wrong -- why sort of, the activity from 1957 to 
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1971, we weren't really seeing the application of 

those low-energy photons, but then before and after 

that period we were.

So I see Rose is bringing up the NIOSH 

document, so if Grady or Scott or one of your folks 

want to sort of walk us through that, I think it 

would be helpful for everyone.

CHAIR KOTELCHUCK: Great.

MR. SIEBERT: Yes, this is Scott. 

Matt, are you on the phone?

(No response.)

MR. KATZ: Matt, you may need to 

un-mute.

MR. SIEBERT: I think you got it. 

MR. SMITH: I just did. I just did.

MR. SIEBERT: Okay. That's Matt 

Smith, our external dosimetry expert. 

So take it away, Matt.

MR. SMITH: Okay. I don't have the 

Skype view in front of me, but this is a little bit 

of a different era at Hanford. It's the era where 

they went to a multi-element film dosimeter. And 

so you end up with values for -- that are titled
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-- beta, X-ray and gamma. And you're correct, as 

you read through it, it's kind of a complex set of 

logic that you have to go through to determine what 

are you going to assign as measured and missed 

doses?

With respect to the question at hand, 

in the Audit Report in Appendix B from SC&A, I'm 

kind of going from Figure 9 in that report, the 

issue specifically was brought up for a situation 

where the beta value was reading zero, the gamma 

result was positive, and then the X-ray result was 

zero. I believe the question then follows: Why is 

there no missed low-energy photon dose applied? 

The write-up kind of goes into the 

scenarios you could have with respect to those 

three values, and this one certainly -- if you look 

at the write-up, it falls into the situation or 

scenario that's shown in row number 1 of Table 1,

that is in the write-up response. In other words, 

again the beta value is zero, the X-ray value is 

zero and the gamma result is positive.

What the tool then assigns is a measured 

photon dose in the 30 to 250 keV range, but no missed 
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low-energy photon dose. And the question then 

follows: Why no less than 30 keV? The rationale 

then hinges on what we see in Table 6-4, which is 

in the Hanford TBD. That particular table is on 

page 31 of 265. And it's data that comes from a 

study done by Wilson and others that looked at 

their --

MR. SIEBERT: And, Matt, I'm sorry. 

Matt, I'm sorry. This is Scott. I just want to 

point out to everybody else it's on page 2 of our 

response, a copy of that table in case you want to 

go down and look at -- yes, there you go. Sorry, 

Matt. Thanks.

MR. SMITH: Thank you, Scott. I'm 

kind of going [on] blind without seeing what the 

rest of you can see.

As you look at that table, if you take 

a look at a source that is showing low-energy --

in other words, photons below 30 keV, you can see 

the result is beta zero, X-ray positive, gamma 

zero. So what we're -- what the tool of logic is 

doing in this situation is taking a look at what 

is measured there, which is positive for gamma, and 
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making the determination that the source that we're 

seeing is likely well above 30 keV. 

If it was a source that contained 

low-energy photons, we feel that we would be seeing 

value in the X-ray column. We can see even at a 

very low exposure level, down around 40 mR, that 

we've got positive value in the X-ray column. So 

without there being a positive value in the X-ray 

column that's why the tool makes the logic decision 

not to assign missed low-energy photon dose.

And I'll stop right there since that was 

the main question in the Audit Report. There's 

obviously other scenarios, but I won't go through 

all of them right now.

MR. BARTON: Well, I do thank you for 

that, Matt.

At this point I think we might want to 

hear from Joe Zlotnicki about the technical aspects 

of using the X-ray, the trigger point. And then 

after that, like you said, you don't want to go 

through the other scenarios, but since you provided 

them in your response, I think we kind of have to. 

But first I think we need to talk 
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about -- essentially if I'm hearing this correctly, 

and I'm going to try to bring it down to my level, 

is that if there's no recorded dose in that X-ray 

component, then it's assumed that there is no 

exposure potential to a source that was less than 

30 keV and thus no exposure would be assigned, 

either a miss or measured. Is that correct? In 

other words, the X-ray is kind of a trigger point. 

Say if you have positive X-ray, it's possible that 

you were exposed to that low-energy source in the 

specific facility. So if we see a positive X-ray 

result in the badge measurement, then it's possible 

that that lower energy photon source would exist. 

Did I have that basically correct?

MR. SMITH: That's a good summary, yes.

MR. BARTON: Okay. Joe, I don't know 

if you're still on the line, if you want to dive 

in first?

MR. ZLOTNICKI: Sure. A couple of 

things. I think everything was sort of explained 

fairly clearly.

If you look at Table 6-4, you'll notice 

that for 16 keV X-rays the dosimeter dose for an 
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exposure of 40 mR showed beta zero, X-ray 40 and 

gamma of zero. If you go down a little bit and look

and look at cesium-137, which we would consider 

high-energy gamma for a 50 mR exposure, you had zero 

beta, zero X-ray and 50 gamma. So clearly the way 

this is laid out, likely practice isn't quite as 

neat as that, but at least in terms of how this table 

is presented there's a pretty clear 

differentiation between the X-ray and the gamma. 

If it's a high-energy gamma, you can see it. If 

it's a low-energy X-ray, you can see it. 

The real question is twofold: One is 

what happened to some extent. And there could be 

a lot of one and a little of the other and vice 

versa. And the second issue is I just realized --

and I've been in and out of this process for years, 

but not the whole time. I just realized that with 

missed dose in general we only give one missed dose. 

We don't give a missed dose if there's nothing seen 

on a dosimeter. 

I don't think we give a beta missed 

dose, an X-ray missed dose and gamma missed dose 

where someone could reasonably have been exposed 
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to them. As far as I know, we only give one. And 

that may be the problem here. This was saying 

there's a positive gamma. We're then saying 

there's no missed X-ray dose.

So I'll stop there because I think 

that's already maybe the crux of it.

CHAIR KOTELCHUCK: Hello? Can 

everybody hear me?

MR. SMITH: Yes, this is Matt. This --

in other words two helpings of missed dose. We 

don't double dip on the missed dose front. The 

tool and the approach with Hanford definitely is 

what I would say claimant-favorable in nature. 

Following again what's in Table 6-4 and when the 

tool was first put together many years ago; I'm just 

kind of jumping back to that Table 1 of our 

response, here's scenario number 2, in other words, 

row number 2 in that table. Here's the scenario 

where we've got positive value in the X-ray, 

positive in the gamma. And therefore, we are 

assigning measured photon dose 30 to 250, measured 

photon dose of less than 30 because of that X-ray 

being positive. 
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Then we're taking the additional 

favorable step of counting a low-energy photon 

missed dose for the zero that's in that beta column. 

So again, going back to the Table 6-4 and just 

taking the scenario probably where you see 59 keV 

there and realizing, hey, 59 keV is indicative of 

working with a plutonium source term. So 

therefore, we took the favorable approach in which 

we'll find some missed dose there. 

Kind of going back though to what Joe 

pointed out, row number 3, if you've got a zero, 

zero, zero scenario across the board for all three 

categories, we assign one missed dose and one 

missed dose only. And we put it to the mid- range 

photon category for photon energy assignment. 

What's the rationale there? We're doing that 

again to be claimant-favorable. That's the 

particular energy range that carries the most --

the highest PoC when it's run through IREP.

I'll just go ahead and proceed on the 

two remaining scenarios. Number 4 is where we've 

got a positive value in the X-ray column only. So 

there we go ahead, we assign the photon dose as done 
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in scenario number 2. And then we also assign 

missed photon dose because of the zero in the gamma, 

30 to 250. 

The very last one, if we were to have 

a positive value in the beta category but then zero 

X-ray, zero gamma, we take a favorable approach. 

We assign the electrons. For beta dose, it's 

low-energy photons and missed dose as 30 to 250 keV 

photons. All of that's favorable for --

(Simultaneous speaking.)

MR. BARTON: This is Bob. I have 

questions on those last two entries.

MR. SMITH: Yes.

MR. BARTON: So for entry number 4 

where we have the positive X-ray and the zero for 

beta and gamma, I think there might be a little bit 

of a typo in the tool results. But basically what 

we're assigning is the measured photon less than 

30, which corresponds to whatever the X-ray 

positive was. Missed photon, because the gamma is 

zero. And then nothing for the beta. Zero. Is 

that correct? Because it would be double dipping 

between the gamma and the beta entries for missed 
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dose?

MR. SMITH: I believe we're saying the 

same thing. The missed dose in that scenario is 

going to be again applied in that more 

claimant-favorable energy range, so we do it 30 to 

250 keV.

MR. BARTON: And it also listed 

measured photon dose, 30 to 250 keV.

MR. SMITH: Yes.

MR. BARTON: So I assume that shouldn't 

be there, right?

MR. SMITH: I'm --

MR. SIEBERT: This is Scott. Yes --

MR. SMITH: I don't have all my notes 

in front of me, but I'm referencing Table 6-2 and 

6-7. 

MR. SIEBERT: Correct me --

MR. SMITH: So probably -- go ahead, 

Scott.

MR. SIEBERT: Yes, correct me if I'm 

wrong, Matt, but my understanding is remember that 

X-ray value is not a stand-alone value. It gets --

really gets portioned out between the shallow and 
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the deep dose. A percentage goes into both of 

those. So if the X-ray dose is positive, it's 

basically considered as a positive shallow dose and 

a positive -- a portion of it's a positive deep dose 

as well. Does that make sense, Matt?

MR. SMITH: Thanks for the refreshing 

reminder, Scott. That's -- and that's why I cited 

Tables 6-2 and 6-7 in that response. You will see 

those tables do discuss the way that Hanford did 

the split on the X-ray component of the dosimeter. 

MR. BARTON: Okay. For row 4 the two 

measured doses, where it says measured photon and 

has the two energies, that's all for whatever the 

X-ray report is. And then the missed photon is for 

the zero gamma. And then the zero beta is ignored 

essentially.

MR. SMITH: Not necessarily ignored, 

but we're are handing out a -- we are going to give 

a missed dose, and we're going to give it in a 

favorable fashion.

MR. BARTON: Okay. Alright. I think 

I understand that one.

If we move onto row 5, however, here 
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you've got a positive beta, a zero X-ray, zero 

gamma. And if I understand the response 

correctly, if you have a zero X-ray dose, then you 

are not exposed to a source that has less than 30 

keV photons, because that would have been picked 

up by the X-ray part of the multi-element 

dosimeter. Is that -- that's correct, right?

MR. SMITH: Yes, and then you see why 

there's a footnote here. We probably put this 

approach in many years ago as a claimant-favorable 

way of assigning the dose. We're calling that 

positive value in the beta -- we're calling it 

low-energy photons. We're also -- 

MR. BARTON: Which it probably 

shouldn't be, though.

(Simultaneous speaking.)

MR. SMITH: -- assigning missed dose. 

Again, see the footnote. This approach was 

initially taken to be claimant-favorable. 

Current evaluation of this approach indicates that 

only missed photon dose should be assigned for deep 

organ dose since the likely source term would be 

an electron emitter.
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MR. BARTON: Right, but if the --

MR. SMITH: Certainly --

MR. BARTON: -- tool was taking that 

positive beta and still assigning it as less than 

30 keV photons, that would not be correct. That's 

what I'm seeing. Because I'm just manually 

working with the tool and putting it in a situation

where you have a positive beta dose, a zero X-ray 

and zero gamma. As far as I can tell, and these 

things are really complex, the tool still returns 

a positive low-energy photon dose where, based on 

the arguments I'm hearing, it really shouldn't.

MR. SIEBERT: But let me clarify. 

This is Scott. What we are presenting in the table 

is how it is presently conducted based on the 

information that was understood a while ago in the 

TBD. We have been looking at this issue for a while 

to determine if that's the most appropriate 

approach and we're honing in on what may be the more 

appropriate way to do it, which is the footnote A. 

However, that has not been a decided factor at this 

point, so no documents have changed to reflect 

that. It's just an interim step at this point.
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Matt, is that a fair assessment?

MR. SMITH: It sure is.

MR. BARTON: Okay. So if it came to 

the point where the approach using the X-ray as a 

trigger, as I put it before, then the tool would 

have to be changed?

(No response.)

MR. BARTON: Is everyone still there?

MR. SMITH: Say that again. If the 

X-ray was --

MR. BARTON: If you had a positive beta 

and zero for the other two components, then the 

correct thing to do would be to only assign the 

gamma deep dose, the 30 to 250 keV and that no 

low-energy photons should be assigned because 

there's no positive X-ray component.

MR. SMITH: Well, it's probably -- as 

stated in the footnote, it's probably more likely 

that this is an electron emitter. In the end --

well, I don't want to speak to the final outcome 

that we're going to do with scenario 5. It 

certainly is a complex one. I don't know if it's 

a common one. It certainly is a rarity when we look 
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at other sites like Savannah River.

Keith, if you're on, if you can -- if 

you have any historical perspective on how often 

we see a positive beta with absolutely zero in X-ray 

and gamma. Everyone on the phone could probably 

appreciate that likely fairly rare situation.

And, Keith, you're going to have to do 

the *6.

MR. McCARTNEY: Okay. This is Keith. 

Can you hear me?

MR. SMITH: Oh, yes.

MR. McCARTNEY: Yes, I don't have a 

handle on what the bulk data looks like as far as 

how often that will occur. I don't look at the raw 

data all that often.

MR. BARTON: Well, if I might, as part 

of the original response; let me see, I want to get 

the exact quote, it says, the appearance of 

omission of missed shallow dose to deep organs 

where a plutonium facility work has been previously 

identified by NIOSH and has been evaluated by the 

Tool Development Group and principle external 

dosimetrist -- which, Matt, I assume that's you. 
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So I guess my question is has this been 

in process for a while, or when did this issue start 

being looked at, particularly in relation to when 

this DR took place? And it kind of almost sounds 

like it's still being evaluated. Is that correct, 

that no determinations have been made on exactly 

how -- or no final determinations have been made 

on exactly how dosimeters, during this particular 

period at Hanford, are going to be interpreted and 

parsed, if you will? 

MR. McCARTNEY: The method that's in 

the tool certainly has been there probably well 

over 10 years. This particular method -- Keith can 

refresh me if I'm wrong -- but it probably went into 

the tool along the same time when OTIB-17 hit the 

street. This particular question came my way from 

two different avenues during the past year. I 

believe I wrote this particular response late in 

2016.

MR. BARTON: I guess -- so at the time 

this DR was done, the interpretation on how you take 

that X-ray component and then interpret low-energy 

photons with the beta component was not actually --
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had not actually been discussed or nor was it really 

part of the overall dose reconstruction program for 

Hanford in this particular dosimeter?

MR. McCARTNEY: That would not be 

correct. It was likely discussed. And like I 

said, those discussions likely took place over a 

decade ago when the tool for Hanford was first put 

together -- not first put together, but when it was 

provided after OTIB-17 came along.

MR. BARTON: Well, I think this issue 

almost kind of goes well beyond obviously this one 

case, and it almost seems like it's a technical 

issue related to the Hanford site as a whole, and 

that -- have final determinations been made? For 

instance with the written response that we have 

now, would that be something that would be added 

to the TBD to explain exactly how these dosimeters 

during this sort of complex time should be 

interpreted?

MR. McCARTNEY: Again, it's something 

that could be added. It will probably help clarify 

the issue. 

In terms of responding to the comment 
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on the claim itself, that was kind of the goal of 

what this effort was. When it comes to revising 

TBDs, when we get that direction, we'll take that 

direction. 

MR. BARTON: Right, and this is sort of 

a situation where the original finding raised the 

question and then we got responses. And that at 

least for me raised more questions about whether 

the tool is acting in accordance with this policy. 

And I think at least for that line 5 it's not, based 

on how I've been sort of manually entering these 

different scenarios, but it also sounds like that 

tool has not been updated in a very long time. And 

so, it might not be reflected on this specific 

issue.

MR. SMITH: And Keith can tell you 

what's wrong with it, but the tool is doing what 

Table 1 states that it's doing.

MR. McCARTNEY: It is doing that. 

That's correct.

MR. SMITH: And the question came to me 

both on scenario number 1, which is the first row, 

and then folks had questions, and this group has 
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had questions about what about this scenario. 

What about the alternate scenario? What about 

scenarios 4 and 5? 

So I stepped through all those and at 

the same time took a look at everything else that 

was available to us and the tools put together to 

come up with this summary of what the rationale is 

or as it was put together as it is now. Does that 

mean that everything is set in stone? I think you 

can tell by our footnote on the last one that we're 

maybe taking a closer look at that one.

But at the same time I believe the last 

scenario was a fairly rare occurrence, whereas the 

ones we see certainly in row one and row three are 

quite common.

MR. BARTON: There's one scenario not 

included here, and that would be positive, zero, 

positive. And again, based on my manipulation of 

the tool, positive, zero, positive still returns 

a low-energy photon dose, whereas -- because that 

X-ray is zero, based on the discussion in your 

response, it doesn't appear that it should.

MR. SMITH: So positive beta, zero 
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X-ray, positive gamma?

MR. BARTON: Correct.

MR. SMITH: And the question again was 

what?

MR. BARTON: When you put in a positive 

beta, zero X-ray, positive gamma, the tool returns 

obviously the measured gamma, but also the measured 

beta as low-energy photons even though the X-ray 

component is zero. And so it shouldn't have 

triggered the application of those low-energy 

photons because the X-ray is zero. And again, that 

will be scenario 6 in this table, which is not -- 

(Simultaneous speaking.)

MR. SMITH: Okay. 

MS. GOGLIOTTI: Bob, you're missing 

that they're assigning the beta dose as low-energy 

photons.

MR. BARTON: No, I realize that, but 

what they're saying is that if there's no X-ray 

component, the X-ray is zero, that it's not 

possible that they were exposed to a source that 

included low-energy photons. So if X-ray is zero, 

there should be no low-energy photon assignment 
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just as a stand-alone rule.

MR. SMITH: I also have to think about 

this in terms of -- I believe the question on the 

computer is saying for deep organ exposure, if we 

have a positive beta on skin, we would tend to -- 

we would assign that as electrons. In this 

situation I think what our aim was as we put the 

tool together was to take a favorable approach to 

things. So by assigning the measured gamma 30 to 

250 keV -- again realizing the X-ray is zero, but 

we've got some value there in the beta column. 

We've decided to assign that as low-energy photon. 

If it's truly electrons, and we're 

talking about a deep organ, we could go one step 

further and say we should not assign any dose at 

all based on what's in that column. So our thought 

process was -- I don't know if it's -- if the tool 

is tying it into the facility at Hanford, but 

certainly I think our thought process was if you're 

at a facility like PFP where you have a plutonium 

source term, we're being claimant-favorable by 

calling what was in the beta column low-energy 

photons. If it's truly electron, you could 
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totally wave it off and not assign anything.

MR. BARTON: Yes, I agree with 

everything you just said. What I'm trying to point 

out is that the tool itself is not necessarily 

logically consistent with the technical arguments 

we see here. And aside from whether those -- the 

technical arguments, which I'll let Joe jump back 

in, because really I just wanted to talk about how 

the tool implements what is discussed here as far 

as that X-ray dose being the trigger to assign the 

low-energy photon dose. I don't think it works in 

all situations. But that's a matter of does the 

tool do what we're saying it should do in all 

situations regardless of what at least for me is 

sort of a new concept of using that X-ray dose as 

a trigger. And again, this might be only 

applicable to Hanford from '58 to '71. I think 

those are the years. 

But aside from any technical concerns 

we had, which again, Joe, I'll let you jump back 

in, I think there is a little bit of a problem with 

the tool. If this method were to be accepted, I 

don't think the tool is doing everything that you 
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folks want it to do.

MR. CALHOUN: This is Grady. Let me 

just ask a question, because I'm kind of confused 

here. Are you saying that if there's a mixed field 

that we should somehow be assigning a blend 

low-energy photon dose that add up to whatever the 

missed dose number would be instead of choosing one 

or the other?

MR. BARTON: Well, Grady, I'm looking 

at the situation, too, and that's essentially what 

you're doing is measured photon for the gamma, 

measured photon for the X-ray, because those are 

both plus, and then on top of that missed dose for 

the low-energy photons. So if it's correct there, 

then -- I mean, I'm just trying to follow the logic 

argument to each of these different scenarios, and 

what's there is not seemingly to me in the tool. 

I mean, I don't know if you folks want to take a 

harder look at that.

MR. CALHOUN: Well, I mean, what we're 

doing though is -- the LOD is going to be a number 

and we're going to assign whatever radiation 

results in the highest Probability of Causation. 
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So if there's an electron component and a 

low-energy photon component, we're not going to try 

to parse those and make those add up to the LOD. 

Am I missing -- is that what you're trying to say 

or not? I'm confused.

MR. BARTON: I'm going to have to 

apologize. I'm not sure I followed your question.

MR. CALHOUN: I'm just not sure what 

you're thinking we should be doing. 

MR. BARTON: Well, let me just say how 

this started up, is that beta is not beta at all 

for this claim. Beta is assumed to be entirely 

low-energy photons until you get to this period 

from 1957 to 1971 in which we're saying, well, we 

have this added piece of evidence, which is the 

X-ray dosimeter element. And if that X-ray 

element is zero, then there's no way that those 

low-energy photons were there, so we're not going 

to assign it. However, that does not seem to be 

logically consistent with what the tool is doing. 

That's what I'm saying. 

MR. ZLOTNICKI: This is Joe. Grady, I 

think what you -- I think you summarized the issue 
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quite well, in that when we have missed dose or 

LODs, you have more than one missed dose, 

potentially. You could have a missed -- there's 

obviously on a photon beta film dosimeter there's 

a missed or an unmeasurable beta dose, an 

unmeasurable low, medium, and high X-ray dose, and 

an unmeasurable limit of detection for the gamma. 

So you've got potentially a mixed field which you 

could imagine followed some complex shape of the 

most dose you could put on that badge and still miss 

it. 

It's a little complicated because if 

you have a little more in one -- for example, beta 

and X-ray overlap in the open window to a great 

degree. And so you can have more of one and less 

of another and still miss it and vice versa.

So I think that the issue is that there 

seems to be, potentially, some inconsistency in 

what happens with that sort of assigned missed 

dose, if there was absolutely nothing measured 

versus if there was something else measured in 

another category, like gamma, what are we putting 

in the X-ray column and so on? 
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I would also add that the sort of sixth 

scenario of beta, no X-ray, and gamma is a pretty 

long shot. I don't know the algorithm for Hanford, 

but I find it hard to imagine that you could get 

a positive result in the beta and gamma column and 

nothing in X-ray. But I don't know that. I just 

think that, the way one constructs algorithms, you 

would wish you could do such a good job of 

separating out the beta. I don't think anyone 

normally manages that, especially not that well. 

MR. SMITH: And we certainly don't see 

it in the Table 6-4 examples.

MR. ZLOTNICKI: Yes, it's too 

difficult. So I think it's a consistency question 

of assigning missed dose and do you assign multiple 

missed doses? Or when you get a measured dose, 

does that mean I don't need a missed dose for 

another category? I think that's the crux of the 

issue. And it probably goes beyond Hanford, by the 

way.

MR. SMITH: I'll just take it back. 

That discussion might be for a different 

Subcommittee. For the purposes of what was in the 
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audit report, I believe we've answered that 

question and I stand by what the tool is doing as 

a claimant-favorable approach to dealing with what 

was brought out in Figure 9 of the audit report.

MR. CALHOUN: That probably is the best 

path forward. I mean, this is looking like -- I 

don't agree that it's a problem, actually, but it 

seems like it's something that could be more into 

an overarching-type issue. But I really believe 

that what we're doing is the claimant-favorable 

approach, because we're not ever leaving any of 

these blank. We're satisfying what the LOD is and 

assigning a radiation dose that results in the 

highest PoC of whatever is the most likely 

radiation that's present. So I agree that I think 

this particular issue on this Subcommittee, we've 

gone as far as we can on that.

CHAIR KOTELCHUCK: Yeah, it seems to be 

that way, too. I mean, I feel like I don't feel 

competent to decide it for a general case and how 

broadly it's applied. But it does seem to me that 

you've taken a claimant-favorable approach by 

always by making an assignment. 
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So I'm not quite sure that would suggest 

that we could close it out. And the question is 

should we refer it to another -- either a Hanford 

Working Group or Procedures Subcommittee. I don't 

know. What do others think? What do other 

Subcommittee Members think?

(No response.)

CHAIR KOTELCHUCK: Can anybody hear 

me?

(Simultaneous speaking.)

CHAIR KOTELCHUCK: Okay. Fine. 

Fine. Good. Okay. Just in case I was on the 

wrong *6.

MR. SMITH: Could you -- could we just 

tackle the first part of your comment first?

CHAIR KOTELCHUCK: Okay.

MR. SMITH: Is there a concern that 

it's a claimant-favorable process that's taken and 

it's simply one of logic now, or questionable 

logic --

CHAIR KOTELCHUCK: Good question. 

Good question. I think it is claimant-favorable. 

What do other Subcommittee Members think? 
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MEMBER BEACH: Dave, I just realized 

that Wanda and I can't answer, so --

CHAIR KOTELCHUCK: Oh, thank you very 

much. So we have --

MEMBER CLAWSON: So it's me.

CHAIR KOTELCHUCK: It's you, Brad, and 

me.

MEMBER CLAWSON: Yeah, so I think it is 

claimant-favorable, but I do agree with him there's 

something odd in this. So I'm just trying to 

figure out who we'd hand this off to.

CHAIR KOTELCHUCK: Yes.

MEMBER CLAWSON: Because I don't 

really think that it would be the Hanford Work Group 

because --

MR. KATZ: No.

MEMBER CLAWSON: -- we're not dealing 

with that. I think this would be in the Procedures 

or something.

CHAIR KOTELCHUCK: Yeah.

MR. KATZ: This is Ted. I mean, when 

we have generic issues like this, that's where 

they'd go. 
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CHAIR KOTELCHUCK: Right.

MR. KATZ: Right?

CHAIR KOTELCHUCK: Well, I'd be more 

than happy. There's also a part of me that we don't 

need -- we're not pressed with a time deadline that 

we must decide this today or immediately in the 

future, and that I could easily send it to the 

Procedures Subcommittee and essentially would 

argue that it's not our purview. Should we come 

back to it again or consider it out of our purview 

at this point?

MR. KATZ: So, Dave, it sounds like you 

and Brad, the standing Members, you can close this 

as far as the Dose Reconstruction Subcommittee. 

If it's claimant-favorable and you think that the 

case is fine as is, you can close the case and still 

ask Procedures folks to take a look at the generic 

issue to see if those issues generically with how 

missed doses, mixed missed doses, is being handled. 

So you can do both. You can close it 

for you and let this case be put away and then send 

the issue over to Procedures to look at.

CHAIR KOTELCHUCK: But I worry -- I 
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mean, that is a reasonable scenario except for the 

fact that I feel Procedures may argue that it's not 

claimant-favorable. I think it is -- and, Brad, 

you think it is -- but I don't feel confident in 

that judgment.

MR. KATZ: Well, yeah, if you just 

don't really feel like you have a handle on how this 

applies even in this case, then -- and you want to 

have the whole procedure looked at, not that it's 

a huge procedure, but want this approach, general 

approach looked at, then, well, the Procedures 

Subcommittee can look at it. 

That's not going to happen quickly, but 

certainly they can do that. If they do that, I 

think SC&A will need to write a little White Paper 

for the Procedures Subcommittee to consider. And 

then we'll need to get a response from NIOSH to 

address their view on the whole matter. And then 

we'll take it up there. That's fine.

MR. CALHOUN: Yeah, this is Grady. 

I'm really thinking that this is going to be pretty 

much of a non-issue, but I agree that we should run 

it to ground. I'm still not convinced that there's 
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a non-claimant-favorable issue here, but I agree 

that, just to put this to bed, if you want to, we 

need a real concise write-up of what exactly is the 

problem and why it's a problem and what would be 

suggested. And then we'll see if that's correct.

MR. KATZ: Right.

CHAIR KOTELCHUCK: That would sound 

good. 

MR. SIEBERT: This is Scott. Can I 

just be clear on who is writing that?

MR. KATZ: So SC&A needs to write up the 

problem. And then following that, a little brief 

memo, White Paper, whatever you want to call it. 

It doesn't have to be extensive, but it just has 

to be clear and complete. And following that, 

then, Grady, your view of -- Scott, your folks can 

give a response to that, and that can be taken up 

by Procedures.

I mean, it can be taken up by the 

Subcommittee, if you want. You can just keep it 

here and get that -- but if SC&A is proposing that 

this is not even just specific to this case, but 

it's a generic issue, then I would suggest it go 
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to Procedures.

MR. CALHOUN: Here's what I propose, is 

that SC&A writes up the problem in a lot of detail, 

because from what I'm understanding, I don't 

understand it all. So they send it back to us and 

we'll take a look at it and see if we can respond. 

And then after that response we'll determine if it 

needs to go as an overarching Procedures Group 

issue. But we'll take a stab at responding to it 

first for this Subcommittee after we receive a very 

detailed write-up of what you think the problem is. 

MR. SMITH: I think that's good.

MR. CALHOUN: Is that okay?

MR. SMITH: I think that's good.

CHAIR KOTELCHUCK: Sounds good. 

Sounds good. 

MS. GOGLIOTTI: Shouldn't this go to 

the Hanford Work Group instead of Procedures? 

CHAIR KOTELCHUCK: Pardon?

MS. GOGLIOTTI: Shouldn't this go to 

the Hanford Work Group instead of the Procedures 

Work Group?

MR. KATZ: No.
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MR. CALHOUN: Not yet, because I think 

it's going to come back as not a problem. 

MR. BARTON: If I might add, this is 

Bob, when I'm mentioning what I call 

inconsistencies between what the workbook is doing 

and what's logic pattern is based on response 

concerning X-rays and low-energy photons, I don't 

believe that it's not favorable to the claimant. 

I believe it is favorable. I just believe it's 

also inconsistent with your logic pattern and 

technical policy here. 

And so I think it would -- I mean, I 

believe that it is claimant-favorable, but I also 

believe that the tool is not performing in line with 

all of the scenarios painted here and the concept 

that the X-ray dose is going to act as a trigger 

to assign low-energy photons.

CHAIR KOTELCHUCK: Well, let me ask 

this. If the two consultant groups both believe 

it's claimant-favorable -- I'm not sure you're 

speaking, Bob, for the consultant group; you are 

speaking as an individual professional. But if 

the group, if you would say that SC&A and NIOSH/ORAU 
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are agreed that it's claimant-favorable, then I 

would close this for the Subcommittee and send it 

to Procedures, which was the first --

MR. CALHOUN: I still want to take a 

shot at proving that it's not a problem.

CHAIR KOTELCHUCK: Well, I'm open to 

that, but if both sides think it's not a problem. 

I understand, inconsistency should go to 

Procedures, but do other -- I mean, I don't know. 

We're not taking a vote between consultants. You 

may want to hear that, but if it's 

claimant-favorable and both sides agree that it's 

claimant-favorable at this point, then I feel like 

we ought to close it for the Subcommittee.

MEMBER CLAWSON: Dave, this is Brad.

CHAIR KOTELCHUCK: Yes.

MEMBER CLAWSON: I agree with you. I 

think that we ought to close it, but I think that 

we ought to -- I'd kind of like to get a read-back 

of it though, too, just because we've dealt with 

this a little bit. But I'd send it to the 

Procedures Group kind of as an overarching issue, 

or it may not even turn out to be anything.
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CHAIR KOTELCHUCK: Yes.

MR. KATZ: Well, that's why -- let's 

get the paper and Grady's response before we 

actually send it to Procedures just so that -- I 

don't want to waste that Subcommittee's time with 

something that ends up being clear to everyone, if 

it should end up clear to everyone, that it's 

actually resolved somehow. 

MEMBER CLAWSON: Okay. That's sounds 

good.

MR. KATZ: Because they're going to 

have to do their homework on this and so on and 

whatever. It's just easier I think than -- keep 

it in this ballpark, even if you want to close the 

case, and we'll hear at the Subcommittee and then 

if necessary will send it over the next time. 

There's nothing lost in doing that.

MEMBER CLAWSON: Okay.

CHAIR KOTELCHUCK: Okay. So you're 

saying it's easier to actually get a write-up?

MR. KATZ: Yeah, for sure.

CHAIR KOTELCHUCK: A write-up in the 

Subcommittee?
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MR. KATZ: Yes.

CHAIR KOTELCHUCK: Okay. It doesn't 

seem to me that way, but you know what, that is 

reasonable. I don't want to do too much tasking. 

And I'd be open. All that means is that we'll get 

something back at the next meeting and we will close 

it, hopefully. Okay. I'll buy that.

Brad?

MEMBER CLAWSON: Yes, I'm good with 

that. And maybe if we get a write-up, I'll even 

be able to understand it better.

CHAIR KOTELCHUCK: Okay. That's 

good.

(Laughter.)

CHAIR KOTELCHUCK: Alright. 

MEMBER RICHARDSON: This is David. 

CHAIR KOTELCHUCK: Yes, go ahead.

MEMBER RICHARDSON: Just to kind of 

follow up once more on this. I guess I would lean 

towards our mission is not simply to -- I mean, if 

there's an issue of logic or if there's a 

calculation that's not doing what's intended, 

regardless of whether it's claimant-favorable or 
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not, I think that's within the scope of what we're 

supposed to be evaluating. So, I mean, that would 

be my view of it. 

So I think Ted's suggestion, then, is 

reasonable and it's a way to move forward, but I 

don't feel comfortable with simply saying, "it may 

not be right, but it's claimant-favorable" as the 

litmus test for what we're doing.

CHAIR KOTELCHUCK: Okay. So that's a 

further argument for going ahead with getting 

something written up for the Subcommittee before 

we send this to Procedures, right?

MEMBER CLAWSON: Correct.

CHAIR KOTELCHUCK: Okay. Then we're 

agreed. I think the three of us are agreed and 

therefore that's our -- that's the decision, if you 

will.

So that takes care of that for the 

moment. And let's go on now. Do we want to go to 

the AWE cases?

MS. GOGLIOTTI: Yes, let me just get 

that pulled up.

CHAIR KOTELCHUCK: Okay. 
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MS. GOGLIOTTI: And, John Mauro, are 

you on the line? 

CHAIR KOTELCHUCK: John?

MS. GOGLIOTTI: John, if you're on the 

line and can hear me but can't talk, press *6, 

please.

CHAIR KOTELCHUCK: Okay.

DR. MAURO: Can you hear me? 

MS. GOGLIOTTI: Yes.

CHAIR KOTELCHUCK: Yes.

DR. MAURO: Oh, it's very unusual -- 

okay. I'm okay now. Very good. Thank you.

MR. KATZ: We have to give special 

credit to Bob Barton for giving us the solution for 

this meeting.

Begin AWE Cases

MS. GOGLIOTTI: Yes, thank you, Bob.

Okay. So we're going to start with tab 360, which 

is the BONUS Reactor in Puerto Rico Nuclear Center. 

MR. SIEBERT: Just to be clear -- this 

is Scott -- this is from the 14 through 18 sets, 

AWE, correct?

MS. GOGLIOTTI: Correct. 
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MR. SIEBERT: Okay. I just want to 

make [sure] we're all on the same sheet of music

there. Thanks. 

MS. GOGLIOTTI: Yes, we have not 

responded to the 19th and 21st sets.

MR. SIEBERT: Okay.

MS. GOGLIOTTI: For AWEs, anyway.

Okay. And this finding states that 

there was a failure to discuss neutron exposure 

potential. And we have talked about this case 

several times in the past. 

And, John, actually I'm going to turn 

it over to you now.

CHAIR KOTELCHUCK: Pardon me, before 

we get started, are the Bethlehem cases closed?

MS. GOGLIOTTI: No.

CHAIR KOTELCHUCK: No, they're not? 

Okay. Well, we want to go to BONUS because we need 

the persons that are here with us.

MS. GOGLIOTTI: Yes.

CHAIR KOTELCHUCK: Okay. Fine. 

Fine. Okay. Thank you. Do go ahead. Sorry.

MS. GOGLIOTTI: John?
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DR. MAURO: Okay. I was just waiting 

to get the green light. Yeah, I'm looking at the 

BONUS Reactor, 360. And I'm going down, there's 

a list there, some are in progress and some have 

been closed.

MS. GOGLIOTTI: Yes, but we're on 

finding No. 2.

DR. MAURO: Oh, very good. That's 

what I'm looking at, and that has to do with neutron 

exposures. 

I looked into this and what we have here 

is we've all agreed that there is, in the BONUS --

by the way, the BONUS Reactor is a BWR 50 megawatt 

electrical experimental reactor that was in Puerto 

Rico. And very often when you're dealing with 

reactors and you have some external exposure -- by 

the way, that issue has been resolved and we're 

comfortable with the one rem per year penetrating 

external exposure. The issue here is, well, what 

about neutron exposures? 

And I think, as Rose pointed out, this 

was discussed before, and there is a little 

ambiguity on whether the reported measured doses 
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from penetrating radiation in the data set, which 

demonstrate that the one rem per year is a good 

number for most workers, and the exceptions are 

known because they were certain events, that for 

this particular person the one rem per year is good. 

The question is, is that one rem per 

year penetrating? Is that the sum of the external 

gamma plus neutron, which could also be a 

contribution to penetrating dose? And that's 

usually a good question, especially for reactors. 

And Grady made the case that, well, yeah, the weight 

of evidence, as indicated in SRDB 9255, page 7, is 

that it appears that they did -- that the exposures 

that we're looking at are really the sum, the 

penetrating, the sum of neutron plus photon. 

And I looked at that and, you know, it's 

hard to say. So we're in a difficult situation in 

that is it really clear-cut that in fact they 

captured the neutron exposures? And I, for one, 

could agree. However, at the same time I could see 

someone arguing, well, let's take a look at other 

BWRs, perhaps such as the BWRs at INL. There's a 

50 megawatt thermal BWR there, and look at the types 
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of exposures there. I don't know if that's a good 

way to sort of convince yourself. 

MS. GOGLIOTTI: I think you're 

actually talking about No. 3, but that's okay. We 

can go to 3.

DR. MAURO: Okay. Am I looking at the 

wrong number right now? Is that what you're 

saying?

MS. GOGLIOTTI: Well, Finding No. 2 had 

to do with the neutron summary.

DR. MAURO: Yeah, that's where I'm at. 

I'm looking at 360.2.

MS. GOGLIOTTI: That's the one, yes.

DR. MAURO: Right. And that has to do 

with the neutron contribution to dose and whether 

or not that's been captured. And the argument is 

made that, yes, in the external penetrating dose 

as derived and assigned to this worker does include 

a neutron dose. And there is some language in the 

write-up that would indicate that it's likely that 

that's the case, or that there wasn't very much 

neutron contribution. 

And my perspective is I would accept 
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that. And, in fact, I think there is also a 

recommendation in here already from the 3/23/2017 

meeting that SC&A recommends closure. I don't 

believe I was involved at that time, but now that 

I'm looking at it, I would agree with that also. 

But I just wanted to --

(Simultaneous speaking.)

MS. GOGLIOTTI: -- that's the response 

that we entered, but --

(Simultaneous speaking.)

MS. GOGLIOTTI: -- records from the 

SRDB that basically established that neutron 

monitoring was happening. But our question was 

really, is the summary table inclusive of that 

neutron monitoring?

DR. MAURO: Yes, and that's what I'm 

trying to explain. And it's difficult to judge 

whether or not it includes or it doesn't. I've 

seen lots of these types of handwritten printouts 

where the penetrating radiation is reported 

separately, gamma from neutron, and where it's been 

combined. 

And all I could say right now from 
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looking at that, it's difficult to judge, but the 

weight of evidence appears to be that, yes, they've 

captured the neutron exposures also. But that is 

very much a subjective judgment. But I would agree 

with that and agree that this issue could be closed 

on that basis, but I wanted to make sure everyone 

else was comfortable with that.

CHAIR KOTELCHUCK: That sounds good 

and I'm onboard with that. It does seem to me the 

argument is persuasive that it has been taken into 

account. What do others think?

MEMBER MUNN: I agree.

CHAIR KOTELCHUCK: Yeah. We're all --

all of us are now participating, so. 

MEMBER MUNN: Yes, we're back.

CHAIR KOTELCHUCK: Right. Brad, 

Josie?

MEMBER CLAWSON: Yes, I'm good.

CHAIR KOTELCHUCK: Okay.

MEMBER BEACH: I'm good also.

CHAIR KOTELCHUCK: Okay. Very good. 

Dave?

MEMBER RICHARDSON: Yes.
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CHAIR KOTELCHUCK: Okay. Good. So 

let's close on that. And then let's go onto 3, the 

360.3 that you started to do a moment ago.

DR. MAURO: Okay. Yeah, I'm looking 

at 3 right now, and this has to do with the internal 

dose. And I'm just quickly refreshing . I read 

it before just to make sure that this is the one 

I'm thinking it is. I believe this has to do with 

a surrogate data issue. 

Now, for this worker, I believe zero 

internal dose was assigned. And the argument 

given was, well, listen, we do not have any internal 

dosimetry data for this worker. Just like they 

didn't have any external, they didn't have any 

internal. 

And in this case they said, okay, how 

are we going to assign some doses, internal doses, 

to this worker? And there's a lot of different 

ways in which you could come at this problem. And 

the way I started was first to say, okay, if you 

go into the SRDB, the number is in here somewhere 

where they give tables of the exposures of workers. 

I believe it's SRDB 16915. 
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And in there they give you lots of data 

for this facility for both external exposures, but 

they also have at the end tables for internal 

exposures. And those tables are blank, and the 

reason they're blank is the heading says you only 

really need -- and the text that goes with it --

you only really need to report internal exposures 

if they're above one-half the maximum allowable 

concentration. 

And so, what we have here is a 

circumstance that could say, well, one could argue 

that this person may have experienced some internal 

exposure, but it was below the reportable level, 

which according to those tables is one-half the --

and at that time it would be the MPCs, if you're 

all familiar with the maximum permissible 

concentrations. And so one can argue, well, maybe 

one-half that value should be assigned, not zero. 

Okay? 

Another strategy could be to assign 

zero, which is what was done, because there's a 

belief -- and I'm having a little trouble with this, 

the belief that there was no internal exposure. 
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Another strategy would be to default to 

what I believe is OTIB-33, which says the 

following: If you have a circumstance where there's 

a reason to believe that a person may have 

experienced internal exposure but you don't have 

any records and you want to assign some internal 

dose, and you know that there was a fairly robust 

health physics oversight program, one could say 

that, well, you could argue that if there was some 

potential for internal exposure and there was a 

good health physics oversight program -- I believe 

the number that's used is one-tenth the MPC as being 

the possible exposure. Because if you're above 

that, the procedures, I believe at that time, in 

1960 this was, it might have been, and I might need 

a little help here, that that's when you kick in 

respiratory protection. So if you're above 

one-tenth an MPC in an occupied area, you want the 

worker to wear respiratory protection.

So another strategy could be to assign 

10 percent. And if you were to do that, that would 

be an effective dose of on the order of 500 millirem 

per year. 
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And then there's the last approach, the 

approach that was elected to be used by NIOSH, which 

was to say, well, let's use as our surrogate the 

outdoor airborne concentrations and associated 

exposures at INL as a default. Well, I tell you 

I really have -- that's in fact what was done. 

That's my understanding, and please correct me if 

I'm wrong. 

I have a real problem with that because 

it comes nowhere near meeting the surrogate data 

criteria. In other words, there's a whole string 

of five criteria for when you use surrogate data. 

That is so far removed from this circumstance, the 

INL outdoor levels, that I really can't -- now, I'm 

not saying that you've got a significant internal 

exposure problem here, but I'm saying that strategy 

for assigning some internal exposure, which in this 

case would be zero -- and the reason it's zero is 

that if the derived internal exposure is less than 

one millirem per year, you assign zero. So the 

actual approach that was used here, and the 

surrogate data strategy, I have a problem with.

I think there are other strategies. 
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The ones I mentioned before seem to be more 

defensible. And it would assign some dose. For 

example, right now he's receiving one rem per year 

whole body external. And in theory if one wants 

to go with the one-half approach that's in that SRDB 

that I mentioned, the one half of the MAC or the 

MPC. Or if you want to go with the OTIB-33 

approach, which is 10 percent of the DAC, the 

derived air concentration, strategy, that would 

seem to be a way to assign some internal dose.

And it seems to me that that would not 

be unreasonable when you look at the reactor 

itself. I had a chance to look at the design of 

the reactor. The whole reactor, everything, is 

inside a dome in containment and there's a 

potential for airborne radioactivity to be 

generated from the steam that's being produced in 

this reactor and sent off to a turbine. And 

there's a control room. So it seems to me there 

is a real potential for internal exposure, and 

assigning zero seems to be difficult to support. 

And that's my story.

And, now, I don't know if I have all the 
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facts correct. So, certainly, Grady, if I got the 

facts wrong -- but if I got the facts right, you 

could understand the rationale for my conclusion. 

And I'm not sure if you would agree with our 

conclusion or not, but I guess there's two steps 

to this. One, did I tell my story correctly about 

the nature of this reactor and also the nature of 

the applicable regulations? And given that, I 

feel that the approach used could be improved and 

some dose should be assigned. 

MR. CALHOUN: Yes, this is Grady. I 

guess I'm not in a real firm position to argue that, 

John. We don't have a ton of stuff on that site. 

We thought that what we did was somewhat 

reasonable. I see your point, too. I don't know 

where to go from here other than try to come up with 

another response. 

MEMBER MUNN: And, of course, one of 

the reasons why you don't have a ton of stuff on 

it is because there was never a ton of stuff there.

MR. CALHOUN: Right.

DR. MAURO: There was an air sampling 

program and there was an attempt to monitor 
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internal exposures. And when you look at the 

tables in that TBD -- I'm sorry, that SRDB 16915, 

you'll see the table where they give you -- there 

would be numbers in there if they were above 

one-half the MPC. 

The way in which the radiation 

protection program worked at this facility at that 

time, which was in the 1960s, around '64, was that 

you didn't worry about it if it was less than 

one-half the maximum permissible concentration. 

And they did not record anything. 

But I would not assign zero. I would 

find a way to say, well, within that context what 

would be a reasonable approach to assign some 

internal exposure? And I offered up a few 

strategies that I would be more comfortable with.

CHAIR KOTELCHUCK: Well, Grady, I 

mean, you're acknowledging that there's some merit 

to what's --

MR. CALHOUN: Yeah, I'm not in a 

position to --

(Simultaneous speaking.)

CHAIR KOTELCHUCK: I mean, it sounds to 
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me as if it might --

MR. CALHOUN: I think we might just 

take another look and come back.

CHAIR KOTELCHUCK: Exactly.

MR. CALHOUN: That's all I can say.

CHAIR KOTELCHUCK: Exactly. I think 

we should just leave it in progress awaiting your 

further thinking and response. And then let's 

take a look at it again. 

MEMBER BEACH: Dave, that sounds 

reasonable.

CHAIR KOTELCHUCK: Okay. Others?

MEMBER MUNN: I don't what else we're 

going to be able to do with it.

CHAIR KOTELCHUCK: Yeah. 

MEMBER CLAWSON: I'm good with it.

CHAIR KOTELCHUCK: Okay. Then I think 

that's what we will do. So that will be in 

progress. 

MS. GOGLIOTTI: Okay.

CHAIR KOTELCHUCK: Alright.

MS. GOGLIOTTI: These next few we've 

carried along, but I think that we got caught up 
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in this past argument and we can actually close 

these next few out. And they both are very 

similar. And the reason that they're two 

different findings has to do with our table. And 

the findings state that there was a failure to 

address monitoring described in the CATI report, 

and also the dose reconstruction was inconsistent 

with the interview.

And on both of those NIOSH agrees with 

us that they could have done a better job addressing 

those things. But then our discussion kind of 

deteriorates and goes back into Finding No. 3, and 

I don't think that we need to keep this open for 

that. Finding 3 we're already leaving open.

CHAIR KOTELCHUCK: Yeah. Okay. 

Again, others?

MEMBER MUNN: Nothing to add.

CHAIR KOTELCHUCK: Okay.

MR. KATZ: Rose, can you just clarify? 

So which are you suggesting be closed?

MS. GOGLIOTTI: Four and five. 

MR. KATZ: Oh, thank you. Okay.

DR. MAURO: They're basically 
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redundant with -- everything really collapses back 

to the issue I just described.

CHAIR KOTELCHUCK: Right. Right.

DR. MAURO: So the others are just 

extraneous.

CHAIR KOTELCHUCK: Yeah. Okay. Four 

and five are closed. Good, I'm glad you asked. 

Okay. Good. What would the next one be? Let me 

just look at my --

MS. GOGLIOTTI: Now we can jump into 

the 409, which is the Bethlehem Steel case. And 

I'm not sure how the Subcommittee wants to proceed 

with these given the discussions that have gone on 

at the last meeting and also in the memo that we 

sent out, as well as the email from Grady.

CHAIR KOTELCHUCK: Now, I'm not -- I 

reviewed these myself. I'm sure others have, too. 

I don't recall in my notes why these were left open. 

They were --

MS. GOGLIOTTI: Well, I think the crux 

of the issue is that when SC&A does a review of a 

TBD that we haven't reviewed -- so when we're doing 

a dose reconstruction of a TBD that we haven't 
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reviewed -- John typically does a kind of mini-TBD 

review just to make sure that the TBD is 

appropriate.

CHAIR KOTELCHUCK: Okay.

MS. GOGLIOTTI: This was kind of a 

unique instance where we did review the Bethlehem 

Steel TBD. And then there was a lot of work that 

went on. And some of those findings were resolved. 

Some of them would be included in a subsequent 

revision.

That TBD was canceled and was replaced 

with another document, and then was subsequently 

revised again. And SC&A has not reviewed either 

of those subsequent documents.

CHAIR KOTELCHUCK: So there's 

TBD-02103, is that it?

MS. GOGLIOTTI: Off the top of my head, 

I don't know the TBD number. 

CHAIR KOTELCHUCK: Yeah, but --

MS. GOGLIOTTI: So that was what 

generated these findings. So they're more 

TBD-related than they are dose 

reconstruction-related.
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CHAIR KOTELCHUCK: Yes.

MS. GOGLIOTTI: NIOSH came back and 

responded to almost all of the findings with a 

generic, this response here.

CHAIR KOTELCHUCK: Yes. Yes. I'm 

going to -- if you don't mind, I'll take a look 

myself now. Thank you. The question is whether 

it's worth going back over --

DR. NETON: This is Jim Neton. I might 

be able to shed a little light on this.

CHAIR KOTELCHUCK: Could you?

DR. NETON: Yeah, there's been some 

back and forth, as Rose pointed out, about the 

reasonableness of entertaining a second review of 

the Bethlehem Steel Site Profile given all the work 

that went into closing it out, oh, 10 years or so 

ago. 

I did review SC&A's memo that was issue 

on the findings that was dated March 29th, 2017, 

and it looks like SC&A has reconsidered some of 

these findings and closed a number of the ones that 

were issued against the Site Profile.

It seems like the -- and I agree with 
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their write-up where in the original review of the 

Bethlehem Steel Site Profile there were --the Board 

did vote to close the findings -- I mean, the Site 

Profile review. But in a sense they left some 

items open that would in today's world be 

considered in abeyance. So I do agree that those 

things were out there and SC&A did not formally 

close those issues. 

So in light of that I think we're 

willing to re-review some of these findings, and 

especially in the light of what SC&A's put out in 

March where I think there's only -- I didn't add 

them up, but I think maybe four findings left that 

are still open for discussion. And we'd be 

prepared to do that. That's not reflected in the 

Board Review System right now.

CHAIR KOTELCHUCK: That's right, it is 

not. Correct. Correct.

DR. NETON: And so I don't know whether 

it would be best to wait to get this matrix updated 

and then we can respond or whether we just want to 

do this sort of ad lib as we go today. We're 

prepared to discuss either way.
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CHAIR KOTELCHUCK: Well, if you're 

prepared to review 409 and narrow down the issues 

that are still open, then it seems to me we should 

accept that and continue and then look at our next 

meeting to discussing what remains. 

What do you think, Subcommittee 

Members?

MEMBER MUNN: I hate to even express a 

comment.

CHAIR KOTELCHUCK: Sure.

MEMBER MUNN: We have, as been pointed 

out, labored long and hard with Bethlehem Steel. 

And we have, I think, in the minds of almost 

everybody, accepted the fact that it was well 

worked. The claimants were graciously treated. 

The decisions with respect to their coverage has 

been certainly claimant-favorable. 

And I guess my question is, are any one 

of these outstanding items of considerable 

significance with respect to dose reconstruction? 

I question that. I haven't sat down and gone back 

through each of them to parse them out in my own 

mind, but given the attention that was focused on 
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it early on, I think it's unlikely that there are 

any truly significant issues that have not been 

adequately addressed. 

So how we resolve what's out there right 

now, I guess, without a small refresher course on 

what exactly are these, quote, "in abeyance" terms, 

each of them, and a decision as to whether this 

might be of real impact to any outstanding claims, 

if there are going to be any in the future, would 

I think be instructive for me.

CHAIR KOTELCHUCK: Right. 

MEMBER BEACH: Dave, this is Josie. I 

think SC&A has submitted their paper. NIOSH says 

they're ready to review it. I see no harm in going 

through both sets.

CHAIR KOTELCHUCK: Yeah. I tend to 

lean that way. This is not a case, I think, of 

resolving outstanding cases that will come before 

us. This really is trying to learn as much as we 

can about -- to review the procedures and make sure 

that the procedures -- but you know what -- no, 

that's not a good argument. Sorry, I retract the 

argument.
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(Laughter.)

CHAIR KOTELCHUCK: I'm not -- I don't 

think I'm coming to a good logical conclusion, but 

I support Josie's feelings that if there is an SC&A 

report and NIOSH is willing it over and report to 

us, maybe it will narrow the -- certainly narrow 

the grounds that we have to make a decision on. Of 

course, those of us who were not there when we went 

through the Bethlehem Steel cases, it's easier for 

us to say we didn't have to suffer as the more senior 

members of our group have. But I think it's worth 

accepting the offer that NIOSH has made.

MEMBER BEACH: Why not?

MR. KATZ: Yes, I mean, this is Ted. I 

mean, Jim's on the line and he's ready to respond, 

so we might as well just -- even if you want him 

to philosophize about what might be the best 

course.

CHAIR KOTELCHUCK: Right.

MEMBER BEACH: Agreed.

CHAIR KOTELCHUCK: Right. Okay. So 

that sounds good.

DR. NETON: Well, but before we do 
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that, I mean, the BRS has not been updated, so I 

don't know how -- we would have to work off of this 

memo.

MR. KATZ: That's fine, Jim. That's 

fine.

CHAIR KOTELCHUCK: Yes.

MR. KATZ: We'll update the BRS after 

the meeting. That's fine.

DR. NETON: Yes, because it's going to 

be substantially different. I think some of these 

went away and others we made these observations.

CHAIR KOTELCHUCK: Good. Good.

MS. GOGLIOTTI: I can certainly update 

it after the meeting. I didn't want to include 

that in here on the off chance that we might 

disagree.

MR. KATZ: Right. And, Rose, if you 

need the transcript after, that's fine. We can 

wait for that, too.

CHAIR KOTELCHUCK: Very good. 

Alright. That sounds like a resolution.

MS. GOGLIOTTI: So is your intent then 

to go over them now or do you want to wait until 
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next meeting to do that?

CHAIR KOTELCHUCK: Next.

MR. KATZ: Now.

CHAIR KOTELCHUCK: Oh, I thought we 

were going to go over it next meeting.

MR. KATZ: Well, Jim's ready to discuss 

it now, so why not --

CHAIR KOTELCHUCK: Because --

DR. NETON: We don't have anything to 

provide in writing, but we can talk about these.

CHAIR KOTELCHUCK: I did not see the --

and it's the -- I was busy on other things, but I 

did not --

MS. GOGLIOTTI: I did not include this 

with the meeting materials, and I apologize.

CHAIR KOTELCHUCK: Right. So I didn't 

get to review that, and so I reviewed the BRS, which 

is as I now understand a little behind. I would --

personally I would prefer to wait until the next 

meeting. I'm not ready to make a judgment. But 

if other people are, then that's okay. If other 

people feel like they've had a chance to -- have 

other people -- well, have other people read the 
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SC&A statement?

MEMBER MUNN: Don't think so.

MEMBER BEACH: Yes, Dave.

CHAIR KOTELCHUCK: You have?

MEMBER BEACH: However, I have no 

objection to having the BRS updated and discussing 

it next meeting, too. So I'm fine either way.

CHAIR KOTELCHUCK: Yeah. Well, I feel 

as if, if it's being presented to us, we should be 

prepared as Subcommittee Members. And I'm not. 

I'm only prepared for discussing what's in the BRS, 

which is out of date. So would it be alright, 

folks? Let's do it next time.

MEMBER CLAWSON: This is Brad. That's 

what I'd like to do.

CHAIR KOTELCHUCK: Okay. Then we'll 

do that.

(Simultaneous speaking.)

MS. GOGLIOTTI: -- and then if you can 

just give us a little preview response of what 

you're planning to discuss in the BRS also. That 

way we can be on the same page.

CHAIR KOTELCHUCK: Okay. 
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MS. GOGLIOTTI: Alright.

DR. MAURO: This is John Mauro. Just 

a quick question. So Jim has had an opportunity 

to look over the issues that require some 

discussion on Bethlehem Steel. It sounds like 

he's prepared to talk about it right now, but the 

preference of the Work Group is, well, let's wait 

until we load up the BRS and everyone has a chance 

to look over the material that SC&A prepared. 

But, Jim, are you preparing to write 

something up, or for the next meeting simply give 

an oral presentation?

DR. NETON: No, I think, John, if the 

BRS is updated in a fairly timely manner, I think 

we should be able to put our responses in there in 

time for the next meeting.

DR. MAURO: Very good. That's all I 

needed. That's great. 

DR. NETON: They're not going to be 

really long. I think that --

CHAIR KOTELCHUCK: No, no need to. 

Right. Short.

DR. NETON: Should be addressed in a 
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fairly short manner. I think there's only four or 

so that I've noticed that really require any kind 

of discussion. And so, yes.

CHAIR KOTELCHUCK: Good. Alright. 

Fine. I think that's appropriate and good. I 

appreciate that. We appreciate that.

So, now, let us see, it is now 3:00. 

This sounds like a good time for a break because 

we've been on since 1:30. Let's take a 15-minute 

break and then come back at 3:15 and continue on. 

How does that sound?

MR. KATZ: Sounds good.

CHAIR KOTELCHUCK: Okay. See you all 

at 3:15 Eastern Daylight Time. Bye-bye.

(Whereupon, the above-entitled matter 

went off the record at 3:00 p.m. and resumed at 3:18 

p.m.)

CHAIR KOTELCHUCK: Where are we next? 

Are we at ElectroMet, 430.2?

MS. GOGLIOTTI: Actually maybe I 

should switch gears, if that's okay with you. I 

know that Hans really has prepared well for his and 

I want to make sure that we get to it today. So 
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does anyone have any objections if we just switch 

gears temporarily and go to tab 434, which is one 

of the DCAS sites, 14 through 18 matrix?

CHAIR KOTELCHUCK: Okay. 

MR. SIEBERT: This is Scott. And I 

apologize, I'm totally fine with that, I just want 

to point out we also have -- this is a day for trying 

to push things out. We have two X-ray findings in 

a couple of the different sets, our X-ray expert 

is retiring at the end of the month, and if we can 

discuss those today, it will be much easier for all 

of us than if we do it -- so after the ElectroMet, 

or whatever you're moving onto, if we could maybe 

prioritize those, I would really appreciate that 

as well.

CHAIR KOTELCHUCK: Surely. And which 

ones are they?

MR. SIEBERT: They are in the 14 to 18th 

Other DCAS set, which it sounds like we're going 

to now already.

CHAIR KOTELCHUCK: Correct.

MR. SIEBERT: 369.3.
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CHAIR KOTELCHUCK: Oh, yes, certainly. 

Okay. Just someone, Rose, somebody keep good 

track because skipping around like this makes it 

hard for me when I'm drafting the next agenda. 

So --

MS. GOGLIOTTI: Trust me, it makes it 

hard for me, too, but we'll keep really good track 

and make sure --

(Simultaneous speaking.)

CHAIR KOTELCHUCK: Right. Okay. But 

I'm chairing. I can't keep good minutes and chair. 

So that's fine. Let's go to the DCAS site and Hans 

and --

MS. GOGLIOTTI: And, Kathy, is Hans on 

the line?

(No response.)

MS. GOGLIOTTI: Kathy, *6.

(No response.)

CHAIR KOTELCHUCK: Okay. 

MS. GOGLIOTTI: Well, maybe we'll 

start with --

MS. K. BEHLING: Okay. Can you hear me 

now?
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MS. GOGLIOTTI: Yes.

CHAIR KOTELCHUCK: Yes.

DR. H. BEHLING: Can you hear me?

CHAIR KOTELCHUCK: Yes, Hans.

DR. H. BEHLING: Okay. I'm having 

problems sometimes with this phone. And, Rose, 

are you going to give Kathy the ability to pull up 

the slides?

MS. GOGLIOTTI: I'm having trouble 

even pulling up the matrix here, so hold on a 

second. 

MEMBER BEACH: Kathy, I pulled mine up 

but it took an extra long time.

(Pause.)

MEMBER CLAWSON: Well, while we're 

waiting, Hans, it's been a long time since I've 

heard your voice. It's good to hear you again.

DR. H. BEHLING: Is that good or bad?

MEMBER CLAWSON: That's good. That's 

good.

CHAIR KOTELCHUCK: My wife and I are 

planning a trip to Berlin later this spring and it's 

nice to get used to hearing a slight German accent.
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DR. H. BEHLING: Yeah. Yeah. No, 

it's a great town to visit. 

CHAIR KOTELCHUCK: So I hear.

DR. H. BEHLING: I was there not too long 

ago with Kathy here. And I was born in Berlin, as 

you may know.

CHAIR KOTELCHUCK: Yes.

DR. H. BEHLING: And we didn't spend 

much time there. We were bombed out in '43, just 

one week after I was born. But I did get a chance 

to visit a little bit later. And again, of course, 

the issue of the war. And it wasn't until in the 

late '90s that I was able to actually go back and 

visit for the first time as an adult.

CHAIR KOTELCHUCK: Ah. Interesting. 

Interesting. Well, it is at the center of much of 

the world's activity, progress, politics, 

whatever, actually for more than a century, for a 

couple of centuries. We look forward to it. 

But, anyway, are we coming up? There 

we are. Okay. 

MS. GOGLIOTTI: I've got it on the 

screen and --
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CHAIR KOTELCHUCK: There we do. 

(Simultaneous speaking.)

CHAIR KOTELCHUCK: We've got it. 

Okay. Very good.

MS. K. BEHLING: Yeah, I'll see if I can 

take control. And if not, I'll just give some 

instruction.

CHAIR KOTELCHUCK: We're going to 

435.1. Is that the first one?

MS. GOGLIOTTI: No, 434.1.

CHAIR KOTELCHUCK: Okay. 

DR. H. BEHLING: And these are two 

findings that I just want to briefly talk a couple 

minutes to give a background as to what these 

findings represent. 

It was back in late 2013 that we were 

given the go-ahead to actually review a dose 

reconstruction that involved the Westinghouse 

Nuclear Fuel Division. And I looked at that 

particular one and provided my review of that and 

submitted the report in February of 2014. And in 

context with the SC&A review of the DR and today's 

discussion about findings, the 1 and 2 findings 
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that we're going to be discussing, it's important 

to note that this particular dose reconstruction 

was based on something other than what we normally 

would expect up to that point in time. That is, a 

Technical Basis Document for Westinghouse, which 

didn't exist. 

And for the guidance in the 

reconstruction of dose NIOSH employed a document 

entitled, "Dose Reconstruction Methodology for 

Westinghouse Nuclear Fuel Division, Cheswick, 

Pennsylvania," which was issued in February of 2013 

as a template.

Now, that was the very first time we 

ever encountered a dose reconstruction that was 

based on a template. And as a matter of fact, it 

was much of a real chore for me to actually go 

through it, because the document, this template, 

was not referenced in the actual DR report, and the 

document had never been acknowledged or identified 

to SC&A prior to the DR. 

And what was more confusing to me at the 

time when I had to look at the DR was the fact that 

this template is actually imbedded, and it's not 
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imbedded as a document such as an attachment, but 

it is actually basically cut and pasted into the 

dose reconstruction as needed, so that when you 

look at it, you are somewhat confused as to what 

we were dealing with. 

And since that time we've obviously had 

a number of discussions regarding the Westinghouse 

facility and the DR. And as a result of these 

discussions, whenever SC&A is asked to review a DR 

that employs a template which has not previously 

been identified or reviewed, our review of the DR 

has to not only look for compliance with the 

template, but since this template has never been 

really vetted, we also have an obligation therefore 

to actually assess the merit of the numbers that 

appear in that guidance document.

CHAIR KOTELCHUCK: Okay.

DR. H. BEHLING: And just to give you 

an overview, I want to go to Slide No. 1, which is 

the first slide. And that really is an overview 

as to what this whole issue is about. Both the 

findings that we're going to discuss briefly really 

are associated with occupational external dose. 
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The first one is for the occupational external dose 

during a residual period. And, as you all know, 

when we do a review, one of our obligations is to 

actually verify each number that is potentially 

important to the dose reconstruction. 

And with regard to the external dose 

during the residual period, this is what the 

template was providing us with in terms of where 

this number came from. And the number that we're 

really interested in here is in the center of the 

page there. It has no table. And this is one of 

the things that most templates have. They don't 

even have a table number, so I can't really refer 

to the table number. But it is the number of 32 

millirem or 0.032 rem that we were looking 

essentially establish as a legitimate number as a 

function of the exposure during the residual 

period.

And in behalf of that, NIOSH assigned 

external doses that would have resulted from 

residual -- and I'm reading under 2.2 there -- that 

explains what NIOSH is doing. NIOSH says it's 

assigning external doses that would have resulted 
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from residual contamination as given by the 

following statements and derived annual doses. 

And I just want to read this into the record:

“External dosimetry should only be used 

to limit residual exposures. Residual exposures 

are calculated based on contamination levels -- and 

I underlined contamination levels -- calculated 

below and applying the dose conversion factors from 

the EPA Federal Guidance Report No. 12 for 

contaminated surfaces and submersion.” These 

doses are provided in the table below. 

And this is the number 32 millirem that 

I was attempting to assess based on those four lines 

of guidance documents that were contained in the 

DR, which are -- which reflected the template that 

goes with that particular facility.

My response, as you see down there 

below, is that -- and I'll just read that again. 

It's says: “NIOSH provides inadequate information 

for characterizing qualifying contamination 

levels at the Westinghouse Nuclear Fuel Division.” 

Residual contamination would have been 

contributed by multiple and complex sources 
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because that's also -- it's not incorporated in 

this statement here, but in other areas of the

template, I was informed that the sources for 

creating the 32 millirem for external exposures 

during the residual period could have come from 

multiple and complex sources that included 

unspecified quantities of 2 percent enriched 

uranium, as well as depleted uranium from the 

Fernald Environmental Management Project. Also 

plutonium from the Hanford facility and natural 

thorium from unspecified sources.

When I looked at that, I said how do I 

go about verifying 32 millirem based on the 

complexity of potential options that were 

available? And this is going to be my discussion 

today in support of my finding that is stated below, 

[an] unsupported method for determining photon 

dose during the residual period.

And let me just go now to Slide 2. And 

as I said, we have discussed this any number of 

times in the past since we issued our original draft 

report for this DR. And you can see here a summary 

of what they are in -- back in 2015, 9/13/2015. We 
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had obviously discussed this, and of course NIOSH 

responded that they had basically used DCFs from 

the EPA Federal Guidance Report Number 12, which 

we already knew about, and applied that to 

contamination levels, which I also knew, but didn't 

have a clue as to what they were. 

And so we went back and forth a number 

of times. And it wasn't really until you come to 

the bottom here where Scott Siebert, less than two 

weeks ago, on the 31st of March, 2017, of this year, 

provided us with two documents as attachments. 

The first one -- the first attachment is the actual 

Westinghouse template which we received for the 

very first time only two weeks ago. Heretofore, 

whenever we had access to that template, as I said, 

it was embedded in the dose reconstruction and very 

fragmented. 

This template now that we have received 

for the first time only two weeks ago, it's a very 

short template. It only consists of six pages and 

covers the entire guidance for the reconstruction 

of doses. Okay? 

The second attachment that was 
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submitted two weeks ago to us, and I'm not even sure 

that we actually received it on the 31st, but it's 

been less than two weeks, was a spreadsheet that 

attempted to explain how NIOSH derived that number 

of 32 millirems for external dose, whole body 

during the residual period.

We then go and spend some time in trying 

to get everyone to understand what it is that that 

spreadsheet has actually provided me in terms of 

informing me regarding the origin of the 32 

millirem per year that we just mentioned in the 

previous slide.

So let me go to Slide 3, which is the 

spreadsheet that I received less than two weeks 

ago. And that requires a substantial amount of 

explanation. And I don't know how well everyone 

could read the slide. It's very small, and it's 

small print, but I need to point out a certain 

number of things. 

This guide on the top portion of this 

slide is really a spreadsheet that defines how 

NIOSH divides the deep dose from photons associated 

with natural thorium. And these are -- the values 
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that you're going to see here are those highlighted 

in yellow. And as I said, the potential source 

terms for creating this could have been natural 

thorium, a plutonium mix of 12 percent, 10-year-old 

recycled nuclear fuel and recycled 2 percent 

enriched uranium. Okay? So those are the 

options. But the ones that are highlighted are in 

fact the ones used that were there to derive the 

32 millirem that I've mentioned.

And so let me go through. On the very 

top left hand corner, one of the critical elements 

that you have to have available to you is an 

understanding of what is the actual starting 

surface contamination defined in disintegrations 

per minute per meter squared? For this 

calculation, and I will talk about that at length 

in a few minutes, is the assigned value of 2.83E^6. 

That means 2.83 million disintegrations per meter 

squared was in fact the assumed starting 

contamination on the basis of which person would 

be exposed to 32 millirem from two source terms. 

The first is the surface contamination 

that's on the floor that the person might be 
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standing on. And that's obviously expressed in 

dpm per meter squared. And as the -- in the second 

column of the top table, you see the 2.83E^6 dpm 

per meter squared. And it's not only applied to 

the natural thorium, but for all the other ones. 

It's a common starting contamination value. Okay?

The next column right over is the 

resuspension factor. And they use the standard 

NIOSH resuspension factor of 1 times 10 to the 

minus-6. In other words, if you have a surface 

contamination of X, you will resuspend one 

millionth of that. And that's the next column. 

In other words, if you apply the 

resuspension value of 1E to the minus-6 times the 

surface contamination of 2.83 million dpm per meter 

squared, you will end up with the value in the next 

column which says that, not only will you be exposed 

to surface contamination in terms of external 

radiation levels, whether there's photons 

involved, simply staying on that contaminated 

surface will give you dose, but also NIOSH, as it 

was described earlier, wanted to incorporate an 

immersion dose. 
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In other words, when you have a 

resuspension value 1 to the minus-6, you also will 

be enveloped by air that contains 2.83 dpm per cubic 

meter of air. Okay? That's less than three dpm 

per cubic meter. And that's a value I hope you will 

keep in mind.

And I won't go through the other columns 

because they're quite complex, but they are 

basically dose conversion factors that are devised 

from the EPA Federal Guidance Document Number 12. 

And when you go through that, you will obviously 

see the effective contamination DCF on behalf of 

the source term that is the contamination on the 

ground. The next one is the effective submersion 

DCF when you're enveloped -- when you're 

standing -- it would be like standing in the -- 

passing plume of a radioactive release that's 

upwind from you. That's the submersion dose.

And when you go -- and then of course 

you go over, and you get obviously the dose rate. 

And then the work hours per year, which is 2,000. 

And when you move a part of those values together 

on behalf of natural thorium, you end with the 
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effective whole body dose on the right hand side, 

which is 0.032 rem per year, okay, which is 

according to the 32 millirem. So we know what in 

essence it did. Okay? 

In the next one below, and I'll go just 

hastily through that, this is the shallow dose. 

This is the dose that will be likely to be received 

as a result of the exposure to a beta component. 

And that would only affect obviously the skin. In 

this particular dose reconstruction, we found this 

wasn't even mentioned, but I need to correct that, 

because as I said, we also have to look at the 

template independent of whether or not some of the 

components of the template were even applied in the 

dose reconstruction. And the reason it wasn't 

applied here is because the cancer involved in the 

EE here was such where the shallow dose would not 

affect an impact.

But anyway, when you get over there, it 

seems like you're using the same values that I just 

mentioned to you, the 2.83E^6 dpm as a starting 

value of the surface contamination, and also using 

the issue of the resuspension, which was obviously 
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less than 3 dpm per cubic meters of air. When you 

come to the very far right hand side, you'll see 

the shallow dose, and the shallow dose based on this 

calculation turns out to be 171 millirem per year.

Okay. And of course that would be the 

starting point for 1973. When we go through the 

left hand side of the slide, you will see for 1973 

the OTP reduction factor is 1.0 between your 

starting point for obviously getting the 95th 

percentile value of the next general dose. Deep 

dose as well, the 95th percentile value of a shallow 

dose contributed by the beta component.

Anyway, so having gone through them, I 

can certainly understand how the value of 32 

millirem was defined by NIOSH. However it is not 

a complete understanding. And the reason is that 

the starting value of the residual surface 

contamination of 2.83x10^6 dpm per meter squared 

for 1973 is simply thrown into this calculation. 

This is the one, the very first number I pointed 

out to you. 

That is core, which is -- obviously 

directly affects the -- all the other calculations 
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that we just went through. In other words, if you 

doubled that value, the starting surface activity 

by 2, instead of 2.83 into something like 5.6 or 

something, you would actually then realize you 

would end up with a deep dose that was twice the 

32 millirem and twice the shallow dose of 171.

So the first question we have to ask, 

how did this number come about? Where did NIOSH 

get this number? So that in essence, had I even 

had more detailed information, the absence of that 

starting contamination value would still have been 

an evasive goal for me to determine.

But the second variable that you have 

to understand also defines those numbers is that 

the natural thorium that you see in this slide here 

is really not a single radioisotope in question. 

In fact, it is the sum total of three isotopes which 

are identified in Slide number 4. And that is the 

issue of what contributes to natural thorium as 

defined by the contribution of thorium-228.

And, Kathy, can you point out where I'm 

pointing at?

Right there is natural thorium you see 
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here. And you see the activity fraction. Okay? 

And for thorium-228, the activity fraction is 

0.084, which means that it represents 

approximately 8.4 percent of the total activity. 

So when we talk about the 2.83 times 10 to the minus

6 dpm per meter squared, the contribution of 

thorium-228 will be expected to give 8.4 percent. 

For thorium-232 the contribution is only 1.45 

percent, and the largest contribution to that 

activity is radium-228 at 90.15 percent. 

In other words, when we look at the dose 

contribution for the external dose, it is not 

equally contributed. What it is is that there is 

obviously -- NIOSH has decided to use an activity 

fraction that somehow or other for natural thorium 

has puzzled me. The question is, when I think of 

natural thorium, in other words, unprocessed 

thorium, you would expect them to be in 

equilibrium. 

And this is -- and the second issue that 

I would not have had knowledge about. And the 

first -- the question that I will leave with NIOSH 

is an explanation as to why the activity fractions 
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that they used for external were anything other 

than the secular equilibrium fraction, meaning 

that the thorium-228, the thorium-232 and the 

radium-228 that you see in that upper left hand 

corner should have been equal in terms of their 

fraction of contribution to the activity. We find 

2.83E^6 dpm per meter squared.

So the only thing I think concludes here 

is that perhaps the activity that was cited here 

was in fact not activity that represents natural 

thorium, but perhaps thorium that has been 

processed, and that these activity fractions 

represent thorium tailings. When you have thorium 

tailings, you've basically removed a major part of 

the thorium with limited amounts removal of the 

radium-228. 

And so, my feeling is that perhaps the 

term that is used here that these -- this whole 

external dose derivation model has simply 

misplaced the word thorium tailings as opposed to 

natural thorium. And that assumption, however, 

would obviously still have a questionable impact 

as we'll see in a few minutes. Because when the 
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assumption of secular equilibriums for natural 

thorium was in fact assumed as shown in the template 

for assessing internal dose -- and I'll go to Slide 

5.

Kathy, can you please go to Slide 5?

Okay. Slide 5 comes directly out of 

the Westinghouse Nuclear Fuel Division template, 

and it represents page number 4 out of the six pages 

for the template. And here you -- obviously in 

dose reconstruction methodology, that involves 

natural thorium ratios for internal. 

And I'm going to point your attention 

to the table. Again, there's no real number 

associated with it. And for natural thorium, we 

see obviously we have these five radionuclides that 

are part of the thorium-232 series, of which only 

thorium-228, thorium-232 and then radium-224 are 

alpha emitters. And anyway, what it really 

suggests, independent of how you want to interpret 

that, the assumption is that they are in secular 

equilibrium. 

And for the internal exposure, again I 

will briefly read for the record how that was 
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explained. And this is -- I'm reading below the 

table there: “Air monitoring results are reported 

in both units of microcuries per milliliters of air 

and in dpm per cubic meter. In most cases, the dpm 

per cubic meter results are more legible on 

record.” And so forth. These results are largely 

from stationary air samples collected on a daily 

basis, et cetera. And I will continue then:

The results are reported as gross total 

alpha activity. A daily weighted average was 

established based on the breathing rate of 9.6 

cubic meters. And that obviously represents a 

breathing rate of 1.2 cubic meter per hour in an 

8-hour day that then totals 9.6 cubic meters per 

day.

In turn, and this is very important down 

here, it states that: “These air sampling data that 

represent this particular table up here were 

defined in a total of 15 different SRDBs that are 

cited here and were evaluated..” -- as I will read 

here further on – “were evaluated for the years '71 

and '72, the operational period for the sites and 

these data. Inhalation/ingestion intakes of 95th 
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percentile were determined as provided in the table 

below.” 

But let me go and -- before I show you 

that table that these documents are now referencing 

in terms of their inhalation/ingestion dose, let 

me go and just briefly tell you now, as a result 

of looking at the spreadsheets that I just 

identified for you, we have a conflict here. For 

external dose, NIOSH assumed obviously activity 

fractions for the natural thorium that don't seem 

to be the dose for a natural thorium process, mainly 

that they're not in secular equilibrium. 

As I mentioned above, the thorium-232 

has an activity fraction of 1.45 percent; 

thorium-228, 8.4 percent. And the bulk of the 

activity fraction goes to radium-228 at 90.15 

percent. Secular equilibrium would obviously 

establish the values of 3.33 for each of those three 

radionuclides.

So for internal exposure, the natural 

thorium did in fact assume secular equilibrium, 

which I just showed you. And so now, you have a 

question: which of the activity fractions that were 
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identified for the external -- why are they 

different from those of the internal, when in fact, 

as I will show you in a minute or so, they represent 

the same potential exposure pathways?

And if it turns out the activity 

fractions that was defined for external doses are 

correct, then the internal photon dose of 32 

millirem and shallow dose of 131 millirem per year 

are correct, and the reference only to natural 

thorium needs to be changed. As I've said, if that 

were the case, then that's easily done. 

However, if the activity fractions used 

for external dose assessments are now applied to 

the internal dose assessments, that currently 

assumes secular equilibrium. Then the reduction 

of internal inhalation/ingestion would be 35 lower 

than we would expect. And this is something that 

I'm going to show you on Slide number 6.

MR. SIEBERT: Well, real quick. This 

is Scott. It seems like we're getting really deep 

into the weeds. It may be helpful at some point 

to have a written --

DR. H. BEHLING: Oh, I do.
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MR. SIEBERT: Fine, but let me back up 

a second. What I'm going to say is -- Mutty, do 

you want to address what we talked about with 

Westinghouse?

Mutty, you may have to hit *6.

MR. SHARFI: Hi, can you hear me?

MR. SIEBERT: Yeah, there you are.

MR. SHARFI: Yes, we identified the 

activity fractions inside the external calc, and 

it was updated in 2014. This claim was done in 

2013. And so the current methodology -- and what 

we provided you with was what was used at the time 

the DR was done -- the current methodology actually 

uses the natural thorium ratios, which actually 

reduces -- which ends up in a reduction in the dose 

conversion factor.

DR. H. BEHLING: Yes, and let me just -- 

and I realize you would probably come to that 

conclusion, but let me just finish up. But I can 

make a point here. 

In Slide number 6, you do have -- again, 

this comes from the actual template itself. It 

comes from page 6, the last page of the template. 
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And it tells you what -- for the un-monitored 

operators and general laborers, what the daily 

ingestion rate would be expected to be. And the 

number I want to focus on is the 965.121 dpm per 

day. 

So if you then go back and say, okay, 

what does that mean in terms of air concentration? 

As I've mentioned before, if you assume 1.2 cubic 

meters per hour, for an 8-hour day, that means 9.6 

cubic meters. And if you divide 965.121 dpm per 

day by 9.6 cubic meters, you end up with 100 dpm 

per cubic meter of air. Okay? 

Now let's go back there and say this is 

what you would have in the air concentration. 

Compare that to the very slide where I said if you 

start out with 2.83E^6 dpm per square centimeter, 

and you apply a resuspension value of E to the 

minus-6, you end up with only 3 dpm, 2.83, less than 

3 dpm per cubic meter. 

And then now you compare that to what 

you would expect in terms of air concentration that 

justifies and/or explains the 965, which is 100. 

So when you divide 100 dpm per cubic meter that 
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would be assumed for the calculation of inhalation 

and ingestion by the 2.83 dpm that you had 

calculated for the submersion dose, under the 

external dose, you have a factor of 35-fold 

difference. Okay?

And the same thing now that if I want 

to continue that extrapolation, saying what if you 

assumed that you actually had an air concentration 

of 100 dpm per cubic meter and say, well, what does 

that represent in terms of the contamination level 

that gives rise to 100 dpm per cubic meter, and you 

use the E to the minus-6 resuspension? You would 

end up with a starting contamination level of 1 

times 10 to the minus-8. In other words, 100 

million instead of 2.83 million. That again is not 

surprising, a factor of 35 difference. 

And so when I looked at those values, 

I said there are inconsistencies here that I cannot 

reconcile. And Mutty, you may have explained it 

to me, and I may have -- 

MR. SHARFI: You wouldn't use the 

resuspension to calculate down, because that 95th 

percent -- the 965 is the operational air 
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concentration. Then you have to settle it, not 

resuspend it. Then you do a reverse resuspension. 

You do a settling calculation. So you do a 

depletion rate of the air and calculate the new 

surface contamination for the start of the residual 

period. And that's what you use in the future.

DR. H. BEHLING: Well, yes and no. 

We're using circular reasoning here because we're 

calculating for 1973. This is now the residual 

area -- time period. And the submersion dose --

MR. SHARFI: Contamination is what 

you're -- you need a starting point. It's not 

related to the operational air concentration. 

It's related to what is settled from operation 

ceasing. This is covered all under 6000. This 

is -- any time you switch from the operational to 

the residual period, you settle the operational air 

concentration to a residual contamination rate. 

Then you resuspend that to get your new residual 

air concentration.

DR. H. BEHLING: Well, I considered 

that circular reasoning because for '73, you 

obviously calculated an air submersion dose that 
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says you are going to get that additional small 

incremental dose from the resuspension of air 

like -- 

(Simultaneous speaking.)

MR. SHARFI: Submersion air dose is not 

settling. 

CHAIR KOTELCHUCK: Pardon? Mutty, 

say that again?

MR. SHARFI: That submersion air 

concentration is calculated based on the 

resuspension of the settled contamination level.

DR. H. BEHLING: Yes, of course. I 

know it is. But if you expect to incur 965 dpm per 

cubic meter per day, that translates into 100 dpm 

for resuspended activity in one cubic meter of air 

during that time. And what does that represent in 

terms of the actual contamination that gives rise 

to that?

MR. SHARFI: Okay. Prior to 1973, we 

have 100 dpm per meter cubed, and we let that settle 

to get a contamination level of about 2 million, 

or 200,000 dpm per cubic meter. Then air 

concentration for 1973 is based on the resuspension 
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of that new contamination level.

DR. H. BEHLING: I don't follow that 

reasoning, I'm sorry. 

MR. SHARFI: This is what's done in 

every AWE per Battelle-6000.

DR. H. BEHLING: I just don't follow 

that line of reasoning. If you're there in 1973, 

and you're exposed to 100 dpm per cubic meter in 

air that you're breathing, that just -- 

MR. SHARFI: You're not. 

DR. H. BEHLING: That has to come from 

a source term that comes from the surface 

contamination. And if you use the resuspension 

factor that we conventionally used in OTIB-70 of 

1E to the minus-6, that would suggest you have 10 

to the 8 dpm per square meter. Simple as that.

MR. KATZ: Well, I wonder if we need to 

get John Mauro on the line since he's very familiar 

with TBD-6000 and the whole issue of resuspension.

MS. GOGLIOTTI: I can certainly get him 

on the line. I might recommend that we write 

something up and send it to NIOSH.

MR. CALHOUN: Yes, that's the only way 
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we can do that. 

CHAIR KOTELCHUCK: Yes.

MR. CALHOUN: This is way too much to 

deal with right now.

MS. GOGLIOTTI: I agree. Plus I want 

to get to the X-ray stuff -- 

CHAIR KOTELCHUCK: Okay.

MS. GOGLIOTTI: -- so we don't lose -- 

CHAIR KOTELCHUCK: Right. Right. 

That is an issue.

DR. H. BEHLING: Can I make a final 

concluding statement? And this is just a very 

short -- it's just one thing. When we deal with 

a template, and we are asked to review the template 

in addition to the compliance of the template in 

DR, we're facing with an incredible chore in trying 

to understand. It took us three years to get this 

document from I guess NIOSH that involves the 

spreadsheet. And without that, I would have been 

absolutely, in no way in a position to verify that 

number. And this is an issue that we do face 

routinely, and it's costing obviously a lot of -- 

MR. KATZ: Well, Hans, this is Ted. I 
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mean, I'm not sure why or what transpired for that, 

but all you need to do is get me involved on the 

front end or something, because you guys can get 

on the line with NIOSH and get that sorted out on 

the first moment. So there's no reason to go for 

three years doing that.

DR. H. BEHLING: Well, we had 

discussions multiple times. I mean, I said I can't 

do this. There is not enough data. And they 

responded, oh, we used Federal Guidance Report 12 

and we used residual contamination. Well, as I 

just went through this, the whole process with you, 

there's no way I could have even come close to 

coming up with -- 

CHAIR KOTELCHUCK: Well, you've 

settled -- I understand what the debate is about 

now, that is, whether you use what is called the 

submersion data or -- and whether you add to that 

the -- 

DR. H. BEHLING: No, no, no, no. It 

doesn't go to that extreme. It means I identified 

the critical components for SC&A to reconstruct the 

doses. I would have meant among all the other 
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things the starting contamination level that was 

assumed and of course the activity fractions I 

would have assumed and the -- 

CHAIR KOTELCHUCK: Okay.

DR. H. BEHLING: Maybe a couple other 

parameters. 

MR. KATZ: Alright.

CHAIR KOTELCHUCK: Okay. Yes, I'm -- 

MR. KATZ: Hans -- 

(Simultaneous speaking.)

CHAIR KOTELCHUCK: You have to put 

something in writing to -- if there's a 

disagreement between the two consultants, the 

Subcommittee has to have something in writing that 

the Subcommittee can, quote, "decide upon or decide 

among."

MR. KATZ: Yes, Dave?

CHAIR KOTELCHUCK: Yes?

MR. KATZ: Hans is now speaking to just 

having all the documentation he needs to be able 

to do a template review. And all I'm saying is, 

whatever transpired in this case, in future cases 

we just need a meeting up front to get all the 
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documentation on the first instance, instead of --

CHAIR KOTELCHUCK: Yes.

MR. KATZ: -- whatever the prolonged 

experience was and why ever it was. But I don't 

think we need to retread that -- this --

CHAIR KOTELCHUCK: True, but --

MR. KATZ: -- going forward. That's 

all.

CHAIR KOTELCHUCK: Right. But right 

now we have this case. We have to have something 

in writing.

DR. H. BEHLING: Okay. And --

(Simultaneous speaking.)

CHAIR KOTELCHUCK: And we've got to 

call this. Hans, it's been a half an hour --

DR. H. BEHLING: Okay.

CHAIR KOTELCHUCK: -- that you've gone 

through this, as I recall. It's been 25 minutes. 

We have several things. We have other people who 

are also leaving, so that we have another person. 

I don't --

MEMBER BEACH: Dave, can I just ask 

a --
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CHAIR KOTELCHUCK: Yes.

MEMBER BEACH: -- quick question?

CHAIR KOTELCHUCK: Sure.

MEMBER BEACH: I just want to 

understand. Hans, were you aware there was a 

template, or just that two weeks ago you became 

aware of the template, or did you just not have data 

for the template, but you knew there was one?

DR. H. BEHLING: No, I knew the 

template -- as I said -- 

MEMBER BEACH: Okay.

DR. H. BEHLING: -- templates are 

usually embedded in the dose reconstruction.

MEMBER BEACH: Okay. I just wanted -- 

because I have that issue with the templates, and 

I wanted to know if you were aware there was one.

DR. H. BEHLING: Yes.

MEMBER BEACH: Okay.

DR. H. BEHLING: And I will quickly say 

I'm sorry I didn't get anything in writing, but I 

was only -- this was a very complex issue going 

through this, trying to decipher everything that 

I just provided in a very quick, hasty way.
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MEMBER BEACH: Yes.

DR. H. BEHLING: I did not have time to 

give you something in writing. 

CHAIR KOTELCHUCK: Oh, that's okay, 

but we do need something in writing. And we 

can't -- like it's hard for us to deal with more 

than that. 

There was another issue that we had to 

talk about because somebody from NIOSH is leaving. 

I don't know if 15 minutes will allow this. 

But which is that? Which cases?

MR. SIEBERT: The first one is in this 

set as well, 369 point -- observation 1.

CHAIR KOTELCHUCK: Okay. Yes, W.R. 

Grace. 

MS. GOGLIOTTI: Okay. Kathy, if you 

could give back control there.

MS. K. BEHLING: Okay.

MS. GOGLIOTTI: And that looks like 

I've got control now. 

MS. K. BEHLING: Okay.

MS. GOGLIOTTI: Alright. 369, 

Observation 1?
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CHAIR KOTELCHUCK: Yes.

MS. GOGLIOTTI: With this one, I 

actually think that with the information NIOSH 

provided we're prepared to close this out. 

CHAIR KOTELCHUCK: Yes, I see. 

Briefly, somebody speak to it.

MS. GOGLIOTTI: I think that we had 

some confusion as to what the filtration was 

representing. And once NIOSH clarified that, the 

issue was resolved in our minds. 

CHAIR KOTELCHUCK: Right, I see. 

Right. This is an observation, and it's been 

clarified. I could accept that with that brief 

discussion.

So Subcommittee Members?

MEMBER MUNN: I have no problem with 

your recommendation.

CHAIR KOTELCHUCK: Yes. Given that 

time is short, but also given that there's a 

clarification made, we're all okay, can I close 

this, please?

MEMBER BEACH: Yes.

CHAIR KOTELCHUCK: Okay. Let's go 
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onto the first finding.

MS. GOGLIOTTI: Was there another 

X-ray one that you wanted to talk about?

MR. SIEBERT: Yes, there's one more 

X-ray one, which is actually the 19th to 21st set 

for Oak Ridge GDPs.

MS. GOGLIOTTI: I think I know exactly 

which one you're talking about.

CHAIR KOTELCHUCK: 359.1, we're not --

oh, it's closed. I'm so sorry. Great.

MS. GOGLIOTTI: But we're jumping now 

to Oak Ridge.

CHAIR KOTELCHUCK: Oak Ridge? Okay. 

Oak Ridge. 19 to 21, Oak Ridge. Okay. I did 

not -- and please tell us which one. I did not 

review that. I did not know that we were going to 

over it, but that's fine. Let's --

MS. GOGLIOTTI: What's the number on 

that? 

MR. SIEBERT: 458.1.

MS. GOGLIOTTI: 458.1.

CHAIR KOTELCHUCK: Okay. 

MS. GOGLIOTTI: Alright. There's 
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been a lot of back and forth on this one. Our 

finding initially was that NIOSH used the female 

lung instead of the male lung. NIOSH provided us 

with some additional information, directed us to 

a different document that we weren't previously 

using. But it also brought to our attention that 

there was a properly collimated beam, even in the 

early years at these sites, which is the Oak Ridge 

sites, all three of them.

CHAIR KOTELCHUCK: Yes.

MS. GOGLIOTTI: And for a properly 

collimated beam, it's our opinion that this 

particular organ, I don't want to give away 

anything, is located in -- outside of the primary 

beam of a chest X-ray. And so our argument -- maybe 

I should let NIOSH go from here, actually. 

MR. SIEBERT: This is Scott. I'm 

going to turn this over to Elyse Thomas.

CHAIR KOTELCHUCK: Okay.

MR. SIEBERT: Elyse, you may have to do 

*6 to be heard.

MS. THOMAS: How's that? Can you hear 

me now?
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MR. SIEBERT: Yes.

CHAIR KOTELCHUCK: Yes.

MS. THOMAS: Okay. And can I not 

mention the organ we're considering here or not?

MS. GOGLIOTTI: Let's just say it's 

part of -- it's -- 

(Simultaneous speaking.)

MS. THOMAS: Well, anyway.

MR. KATZ: Elyse, we don't have any 

details on this other than organ and the whole big 

site, which is huge, so I think you're fine 

mentioning it.

MS. THOMAS: Okay. The organ we're 

discussing is the small intestine. And there is 

not a specific dose conversion factor for that 

organ. And so the dose to that organ has to be 

determined using some other dose conversion 

factor. And the critical thing for the dose is 

whether the organ is in the beam or out of the beam. 

So that organ is really located all over from the 

upper abdomen and the lower abdomen. And even for 

a properly collimated chest X-ray, it's possible 

that portions of that organ that are up under the 
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diaphragm and near the liver and gall bladder and 

spleen could be in a properly collimated beam. 

And so the dose reconstructor used a 

substitute dose conversion factor of the lung as 

a more claimant-favorable assumption. If the dose 

reconstructor would have used a substitute dose 

conversion factor in the lower abdomen, that would 

be representing a situation where it's out of the 

beam and would result in a lower dose.

So in the case where there's not an 

organ-specific dose conversion factor to use, the 

dose reconstructor used a more claimant-favorable 

option. Does that make sense?

(No response.)

MS. THOMAS: We don't disagree that 

that's claimant-favorable, but we don't interpret 

OTIB-6 to mean that. OTIB-6 specifically says use 

the dose correction factor for the ovary as a 

substitute organ in the lower abdomen such as --

and although the lower intestine isn't mentioned, 

the colon is mentioned.

CHAIR KOTELCHUCK: Right.

MS. GOGLIOTTI: And most people would 
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say the colon would be above the lower intestine. 

I don't think that that's even in debate. And if 

you're going to include the colon in the lower 

abdomen, then you should be including the lower --

or the small intestine also in that same category. 

That would be my logic. 

MS. THOMAS: I mean, I don't think 

we're ever going to know for this particular person 

exactly where that organ is and whether it was in 

the beam or not. So --

MS. GOGLIOTTI: I agree, and perhaps 

OTIB-6 needs to specifically say for these 

instances use that, but the lower intestine is not 

mentioned in OTIB-6.

CHAIR KOTELCHUCK: Well --

MS. GOGLIOTTI: So is it 

claimant-favorable? Yes. But from OTIB-6, I 

think that's a reasonable interpretation that it's 

on you, the lower abdomen would include the small 

intestine.

CHAIR KOTELCHUCK: Sounds like it. 

The question is, is OTIB-6 being interpreted 

correctly? And choosing the lung appears to 
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contradict OTIB-6.

MS. THOMAS: I don't think so. I mean, 

the small intestine is not mentioned in OTIB-6.

MS. GOGLIOTTI: Correct. However --

CHAIR KOTELCHUCK: Colon is.

MS. GOGLIOTTI: -- the colon is.

MS. THOMAS: Yes, but the small 

intestine -- the colon. The small intestine is a 

much larger organ in terms of --

MS. GOGLIOTTI: Yes.

PARTICIPANT: And how are they 

differentiated? It's essentially the entire 

abdomen.

MS. THOMAS: Yes, I had submitted a 

cross-sectional diagram to Scott when I --

MS. GOGLIOTTI: You did, and it's 

actually listed --

(Simultaneous speaking.)

MS. THOMAS: Yes.

MS. GOGLIOTTI: Oh no, I closed it.

CHAIR KOTELCHUCK: Can we see it?

MS. THOMAS: Anyway, the 

cross-sectional diagram --
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MS. GOGLIOTTI: Yes.

MS. THOMAS: The bottom of the chest 

and --

MS. GOGLIOTTI: I do agree with that, 

but this is the transpyloric plane, and I don't see 

how -- I understand that it's showing that the lower 

intestine or the small intestine can be in the 

claim, but is that -- is there something with X-ray 

that I'm not getting where that claim is always 

included in the chest X-ray?

MS. THOMAS: Well, I mean, you can't 

say that it couldn't be. It's very possible it 

could be.

CHAIR KOTELCHUCK: I wish there was a 

section, not a horizontal, but a vertical. I mean, 

I'm concerned that my understanding of the biology 

of the location of the duodenum is -- where does 

it lie? 

MS. GOGLIOTTI: The duodenum would be 

about right here.

MEMBER BEACH: Yes, it looks like it's 

right in the middle.

CHAIR KOTELCHUCK: Yes.
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MS. GOGLIOTTI: And so -- and my 

interpretation with duodenum would be the small 

intestine reference here.

CHAIR KOTELCHUCK: Yes.

MS. GOGLIOTTI: It seems like the 

stomach is connected --

(Simultaneous speaking.)

CHAIR KOTELCHUCK: Yes.

MEMBER BEACH: Yes.

CHAIR KOTELCHUCK: Yes. 

MS. THOMAS: Yes, let me read a 

sentence from -- this is right from OTIB-6. And 

it says: “For properly collimated beams in general 

for chest, thoracic and cervical spine X-ray, a DCF 

for lung is used for other organs in a thoracic or --

or upper abdominal cavity.” 

So I don't know how -- I don't think 

OTIB-6 is inconsistent with what the dose 

reconstructor did. Or I should say that the other 

way around. I don't think what the dose 

reconstructor did is inconsistent with OTIB-6.

MS. GOGLIOTTI: Yes, I would say that 

that's a gray area in OTIB-6.
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MS. THOMAS: It is. It's a gray area 

because we never really know for any given 

individual where exactly their organs lie. Some 

people have kidneys that are in different 

locations. We never really know that for a given 

individual, so we have to -- 

MS. GOGLIOTTI: I agree, but at that 

point, you might as well just assume everything is 

part of the primary beam in the main torso.

MS. THOMAS: Well, I think that's a 

little bit of a stretch, but it is 

claimant-favorable.

MEMBER BEACH: It is 

claimant-favorable.

MEMBER MUNN: Well, it's hard to 

imagine. I mean, even people who are familiar with 

X-ray are hard-pressed to assure that the colon is 

always as clearly differentiated as you want it to 

be. And since the placement of the small intestine 

is arguable with any single organism, I think, the 

probability -- you wouldn't anticipate that the 

entire organ had been exposed, but that's not the 

argument here, as I understand it. They're 
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recommending -- the idea is that a portion of it 

might have been, and it would be not unreasonable 

to assume that there's a possibility.

MS. GOGLIOTTI: Right. 

MEMBER MUNN: So it's kind of a 

catch-22.

MS. GOGLIOTTI: So for my first 

argument here, the small intestine, every single 

time you assume that the small intestine is part 

of the primary beam when it's properly collimated 

or not properly collimated, is that a consistency 

that NIOSH always does? Because I'm not sure you 

could argue that. Or maybe that's something you 

always do, but I don't see evidence here that that's 

consistent.

MS. THOMAS: Well, I don't know that I 

can categorically say that, but I think I could say 

that dose reconstructors would, if they had a 

choice between using this substitute organ dose 

conversion factor or this one, they would choose 

the claimant-favorable one. That I think I could 

probably categorically say.

MR. CALHOUN: This is Grady. This is 
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another one I don't know where we're going with 

this. 

MS. GOGLIOTTI: And I don't think we're 

going to come to a resolution.- 

MR. CALHOUN: We're not. It seems 

like two people that seem to know what they're 

talking about, have a difference of opinion. And 

I don't really see any proof that we're wrong from 

SC&A's standpoint, so I just as soon we just leave 

it the way it is and move on because there's -- it's 

just going to be we agree to disagree. And I think 

that's all that [this] is. 

MS. GOGLIOTTI: I agree, but I'm just 

going to -- I want to point out that the Board has 

been focused on areas where there's consistency 

which could potentially impact the case. This is 

a consistency issue. I mean, with that, the Board 

can do what they want with it, but I want to point 

that out.

CHAIR KOTELCHUCK: Yeah. But the 

Subcommittee has to do something with it. I mean, 

we've got to take a stand, if you will, one way or 

the other.
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By the way, we're at what, 369.3, or 

it's W.R. Grace.

MS. GOGLIOTTI: This is 458.1.

CHAIR KOTELCHUCK: Pardon?

MS. GOGLIOTTI: This is 458.1.

MEMBER MUNN: 458.1.

CHAIR KOTELCHUCK: 458.1? Okay. 

Because I'm looking at the -- I'm just looking at 

the -- I'm looking at the Skype. So, now let's see. 

Yes, there it is, 458.1. Okay. Sorry.

So I think we -- look, time is running 

short. It's 4:15. I think we should talk about 

it again. I don't think we're ready.

MR. KATZ: This is Ted. Can you hear 

me?

CHAIR KOTELCHUCK: Yes, I can.

MR. KATZ: Oh, can I just make a 

suggestion?

CHAIR KOTELCHUCK: Yes.

MR. KATZ: Because I think, I mean, 

both sides have agreed it's claimant-favorable and 

that it's a gray area in terms of it's an 

uncertainty. And in cases of uncertainly you're 
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supposed to do what's claimant-favorable. So I 

think you guys can actually close the case. 

On the other issue that Rose raises, 

which is a reasonable issue, is, well, is it handled 

consistently, I think then you need to have an 

analysis to see whether or not it is handled 

consistently. Maybe this is always handled 

consistently. Rose doesn't know yet, but she 

didn't do a review of that. But we could do -- we 

could look at that separately. That's really an 

issue for the Procedures Subcommittee, or Dose 

Reconstruction can have it. You can talk it either 

way. But I think you can close the case if both 

sides agree that this is claimant-favorable and 

it's reasonable to do since there's uncertainty 

about the location of this organ.

MS. GOGLIOTTI: I agree, Ted.

MR. KATZ: Yes.

CHAIR KOTELCHUCK: Subcommittee 

Members?

MEMBER MUNN: I agree.

MEMBER CLAWSON: I agree with Ted.

CHAIR KOTELCHUCK: Okay. I'll go 
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along with that. I'm not quite actually convinced 

but I respect -- then let's go with that. Close 

it and refer to the Procedures Subcommittee.

MR. KATZ: Yes, well, even that, I 

mean, before even -- Rose, can I just -- Dave, with 

your leave, let me just ask Rose to -- Rose, why 

don't you just look at a sample that's -- not 

looking at you, Rose, of course, but someone just 

take a look at a sample of dose reconstructions 

where this comes into play and see if they've been

handled consistently. You have lots of dose 

reconstructions that you have in your files already 

that you could probably catch a few to just see.

MS. GOGLIOTTI: Yeah, I'm sure that we 

have them there. 

CHAIR KOTELCHUCK: Good. That would 

be helpful. And could you report back to us next 

time? And then we will perhaps refer it, or 

perhaps not. 

MS. GOGLIOTTI: Okay. Yeah, we can 

absolutely do that. And we'll just -- 

(Simultaneous speaking.)

CHAIR KOTELCHUCK: Good. Good. 
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Okay. Let's -- folks, we need to pick a date. 

MEMBER MUNN: How far out are you 

looking?

MR. KATZ: Yes, well, it has to be at 

least two months out these days given this 

administration. So it would have to be two months 

or more out.

CHAIR KOTELCHUCK: So that's the 

middle of June.

MR. KATZ: Yeah. And then the second 

question is a little -- do we have plenty of work 

or will we have plenty -- we have three more blinds 

to discuss from this set, right, Rose?

CHAIR KOTELCHUCK: Right.

MS. GOGLIOTTI: Yes.

MR. KATZ: But beyond that, do we have 

plenty of fodder that will be ready in two months' 

time? And that question is to both sides.

MS. GOGLIOTTI: I would like to get 

started on another matrix if NIOSH is close to 

getting us another -- responses for that. That 

would give us plenty to talk about. We still have 

a full matrix that we haven't discussed, but -- 
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CHAIR KOTELCHUCK: Which one?

MS. GOGLIOTTI: The Oak Ridge matrix 

for the 19th to 21st set, other than this particular 

case, we have not discussed at all.

CHAIR KOTELCHUCK: True.

MS. GOGLIOTTI: And then there's two 

matrices that NIOSH has not responded to. And 

that's all of our findings.

MR. SIEBERT: Right, and this is Scott. 

I believe we're almost done with one of the other 

two that are outstanding. I'm assuming that we'll 

get uploaded probably halfway between now and the 

next meeting. 

And I do have a question, since you 

mentioned the rest of the Oak Ridge cases. Did 

SC&A categorize these Category 1 and 2 for that set 

and I just missed it or --

MS. GOGLIOTTI: We did. That was in 

the meeting files. I can send it to you 

separately, if you'd like.

MR. SIEBERT: Yeah, that would be 

really helpful, because digging through all those 

files I -- it's hard for me to get the files over 
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on the ORAU -- on the DCAS server. We're going to 

have to do some shifting. So that would be very 

helpful. Thank you.

MS. GOGLIOTTI: Okay.

MR. KATZ: Okay. So then the -- 

MEMBER MUNN: May I suggest the last 

week in June?

MR. KATZ: For scheduling, yeah, we can 

start with that week, the week of June 26th. How 

does that week look to start with?

CHAIR KOTELCHUCK: It's okay with me. 

MEMBER BEACH: It's fine with me.

CHAIR KOTELCHUCK: And, Brad?

MEMBER CLAWSON: Yeah, it looks good.

MR. KATZ: Brad, is there a better day, 

a worse day during that week?

MEMBER CLAWSON: No. If it's the 

26th, I've just got -- I would have had to have left 

by now -- 

(Simultaneous speaking.)

MR. KATZ: What about the 27th?

MEMBER CLAWSON: That would be better, 

to tell you the truth. 
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CHAIR KOTELCHUCK: Which one? 

MR. KATZ: The 27th of June.

MEMBER CLAWSON: Twenty-seventh.

CHAIR KOTELCHUCK: Okay with me.

MR. KATZ: Is that okay with you? 

Okay. So let's do that as a tentative date. 

CHAIR KOTELCHUCK: And, David, are you 

still on the line?

(No response.)

CHAIR KOTELCHUCK: Okay. So you need 

to check with David and John.

MR. KATZ: So, well, first, let me just 

check and see. The 28th, 29th and 30th, are those 

all also fine for everyone on the line?

MR. CALHOUN: Okay with Grady.

MEMBER BEACH: Except the 30th, if 

possible.

MR. KATZ: Okay. The 28th and 29th 

okay?

MEMBER BEACH: Are good.

CHAIR KOTELCHUCK: Yeah.

MR. KATZ: Okay.

MEMBER CLAWSON: The only one that 
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doesn't work for me, Ted, is the 28th because I've 

got a three-hour meeting that would have been -- 

CHAIR KOTELCHUCK: Okay. So we have 

the 27th with the 29th as backup. 

MR. KATZ: The 29th as an alternate. 

So let me just get one more date, because that's 

all the same week and who knows, the other date may 

be -- 

CHAIR KOTELCHUCK: Yes, right. I'm 

worried that -- right, and I'm also worried that 

I have grandfatherly duties, and it might come that 

week. If it doesn't, I'm going to be fine.

MR. KATZ: Okay. So then let's skip 

the following week, because that's the week of the 

4th of July. That's usually terrible for 

scheduling. 

CHAIR KOTELCHUCK: Right.

MR. KATZ: But let's talk about the 

week of July 10th. How is, for example, the 11th?

MEMBER BEACH: Fine.

MEMBER CLAWSON: That's good with me.

CHAIR KOTELCHUCK: Hey, good. That's 

one is more likely to be good for me.
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MR. KATZ: Okay. So that's another 

tentative.

CHAIR KOTELCHUCK: Right. Honestly, 

if I had my choice, I know I could do the 11th. I'm 

not sure I could do either of the other two, but 

I'm pretty sure it's okay. I could check within 

a day or two.

MR. KATZ: Okay. So just to make it 

easy, let's just make that our favored date.

CHAIR KOTELCHUCK: Would that be okay, 

folks?

MR. KATZ: Is that okay with everyone 

else?

CHAIR KOTELCHUCK: Did you say July 

11th? And then the backup will be one of the two 

days in the previous week.

MR. KATZ: The backup will be the 27th 

or the -- 

CHAIR KOTELCHUCK: And I will be there, 

if need be.

MR. SIEBERT: This is Scott. Let me 

throw this out. I don't know if it impacts 

anybody, but I believe July 11th is during the HPS 
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meeting this year.

CHAIR KOTELCHUCK: Ah.

MR. KATZ: Oh, wow. That's terrible 

this year.

CHAIR KOTELCHUCK: Yes, okay. That 

sets it back. Well, then -- 

MR. KATZ: And that really is no good, 

because that may impact -- I don't know, Grady, does 

it?

CHAIR KOTELCHUCK: Surely.

MEMBER MUNN: Yeah, too many people.

CHAIR KOTELCHUCK: Okay. We'll -- 

MR. CALHOUN: I'm fine. I'm not 

going, but we need Scott here.

MR. KATZ: Yeah, we do need Scott, yes.

CHAIR KOTELCHUCK: Well, make it the 

27th and 29th.

MR. KATZ: Oh, no, but we still need 

another week. So then -- 

CHAIR KOTELCHUCK: How about the 

following week? Now, excuse me, the previous 

week.

MEMBER MUNN: But that's a holiday.
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CHAIR KOTELCHUCK: Is it?

MS. GOGLIOTTI: The annual meeting -- 

MEMBER MUNN: No.

CHAIR KOTELCHUCK: No, no, I'm talking 

about the previous week in June, the week of June 

19th.

MEMBER MUNN: Is that enough time to 

get -- 

MR. SIEBERT: This is Scott. I'm out 

that week.

CHAIR KOTELCHUCK: Okay. Fine. 

MR. KATZ: Okay. No, and actually the 

following week -- I'm out at a meeting that 

following week.

CHAIR KOTELCHUCK: Okay. 

MR. KATZ: That puts us to the week 

of -- oh, wait. Okay. So that means let's look 

at the week of July 24th. So how about the 25th? 

That's a Tuesday again for Brad.

MEMBER MUNN: We have ABRWH. We have 

a full-scale meeting, don't we?

MR. KATZ: No. No, that's in August. 

I'm talking about July. 
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CHAIR KOTELCHUCK: Yeah, okay.

MR. KATZ: July 25th.

CHAIR KOTELCHUCK: Okay.

MR. KATZ: Does that work for everyone?

MEMBER BEACH: Sure.

CHAIR KOTELCHUCK: Sure.

MR. KATZ: Okay. 

MEMBER BEACH: Ted, it's not perfect 

for me. My grandson is due, but you know that's 

up in the air, so -- 

CHAIR KOTELCHUCK: Yes.

MR. KATZ: Oh, yes.

MEMBER BEACH: But I'll know more 

closer, so. 

MR. KATZ: Then if you're waiting on 

a -- that could be any time then.

MEMBER BEACH: Well, that's the date, 

that's the due date, so --

MR. KATZ: Oh, no, but the due date 

is no more accurate than -- 

MEMBER BEACH: Exactly.

MR. KATZ: Yeah. Okay. So that's a 

tentative backup date. Tentative.
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CHAIR KOTELCHUCK: Okay. 

MEMBER MUNN: Backup? Okay. 

MR. KATZ: Okay. And, Dave -- 

CHAIR KOTELCHUCK: And I'll check on my 

thing very quickly.

MR. KATZ: Yeah, if you'd just get back 

to me, I'll switch which is the actual date if, 

Dave, if you tell me in the next couple days -- 

CHAIR KOTELCHUCK: Oh, I will. I 

will. I'll find out fast. 

MR. KATZ: Okey dokey. 

CHAIR KOTELCHUCK: Alright. Thank 

you, all, folks.

Adjourn 

MR. KATZ: Yes, thanks, everybody.

MEMBER CLAWSON: We'll see you.

MEMBER MUNN: Bye-bye.

MEMBER BEACH: Bye-bye.

(Whereupon, the above-entitled matter 

went off the record at 4:25 p.m.)
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